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IN THE UNITED STATES BANKRUPTCY COURT 
FOR THE WESTERN DISTRICT OF WASHINGTON AT TACOMA 



In Re : 


) 




SUSAN FAYE DONES, 


J 




Debtor . 


) Bankruptcy 
) No. 10-4560E 


i-BDL 


NXIVM CORPORATION, a Delaware 
corporation , 


) Adversary 
) No. 10-0433E 


i-BDL 


Plaintiff, 






vs . 






SUSAN FAYE DONES, 






Defendant . 






VIDEOTAPED DEPOSITION OF 


SUSAN F. DONES 




November 23, 


2010 





Tacoma, Washington 



Byers & Anderson, Inc. 
Court Reporters /Video /Videoconferencing 



One Union Square 
600 University St. 
Suite 2300 
Seattle, WA 98101 
(206) 340-1316 
(800) 649-2034 



2208 North 30th Street, Suite 202 
Tacoma, WA 98403 

(253) 627-6401 

(253) 383-4884 Fax 
scheduling@byersanderson . com 
www . bye r sander son . com 



Serving Washington's Legal Community since 1980 



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APPEARANCES 

For the Plaintiff: 

Robert D. Crockett 

Latham & Watkins 

355 South Grand Avenue 

Los Angeles, CA 90071-1560 

1.213.485.1234 

1.213.891.8763 Fax 

bob.crockett@lw. com 



For the Defendant: 

Susan F. Dones, Pro Se 



Also present : 

Cody Malone, videographer 



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EXAMINATION INDEX 



EXAMINATION BY 



PAGE NO 



Mr. Crockett 



EXHIBIT INDEX 



EXHIBIT NO 



DESCRIPTION 



PAGE NO 



Exhibit No. 1 



2-page e-mail from Susan Dones 
dated 10/21/10. 



14 



Exhibit No. 2 



3-page e-mail from Susan Dones 
dated 10/21/10. 



18 



Exhibit No. 3 



2-page intensive program 
application . 



34 



Exhibit No. 4 



2-page intensive program 
application . 



36 



Exhibit No. 5 



1-page 12 point mission 
statement by Keith Raniere 



37 



Exhibit No. 6 



5-page confidentiality 
agreement . 



42 



Exhibit No. 7 



1-page letter to Susan Dones 
from Robert D. Crockett dated 
3/22/10 . 



76 



Exhibit No. 8 



1-page document titled 
"Schedule B - Personal 
Property . " 



86 



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BE IT REMEMBERED that on Tuesday, 
November 23, 2010, at 1201 Pacific Avenue, Suite 1200, 
Tacoma, Washington, at 10:38 a.m., before Valerie L. 
Torgerson, Certified Court Reporter, RPR, appeared SUSAN 
F. DONES, the witness herein; 

WHEREUPON, the following proceedings 

were had, to wit: 



THE VIDEOGRAPHER : Good morning. We 
are now on the record. My name is Cody Malone, 
videographer for Byers & Anderson Court Reporters and 
Video. We are located at 2208 North 30th Street, 
Suite 202 in Tacoma, Washington 98403. The telephone 
number is 2 5 3-627-6401. Today's Tuesday, the 23rd day of 
November, and the -- 2010. The time is now 10:38 a.m. 

This is the video recorded deposition of Susan Faye 
Dones -- or Dones being taken in the case of Susan Faye 
Dones, Debtor, and NXIVM Corporation, Plaintiff, versus 
Susan Faye Dones, Defendant. The cause numbers are 
Bankruptcy No. 10-45608-BDL and Adversary No. 
10-04338-BDL respectively in the United States Bankruptcy 
Court in and for the Western District of Washington at 
Tacoma. This deposition is taking place at the offices 



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of Eisenhower & Carlson, PLLC, at 1201 Pacific Avenue, 
Suite 1200, in Tacoma, Washington, and was noticed to 
begin at 10 a.m. 

I would ask the counsel present to please identify 
yourself on your record. 

MR. CROCKETT: Robert Crockett for the 

plaintiff . 

THE VIDEOGRAPHER : Thank you. The 
court reporter today is Valerie Torgerson of Byers & 
Anderson. If you would, please swear in the witness and 
proceed with the deposition. 

Susan F. Pones , having been first duly sworn 

by the Notary, deposed and 
testified as follows: 

EXAMINATION 

BY MR. CROCKETT : 
Q Ms. Dones, have you ever been deposed before. 
A No , sir . 

Q Can you please state your full name? 
A Yes. It's Susan Faye Dones. F -- 
Q And what 

A F-A-Y-E is the spelling of the middle name. 
Q What's your date of birth? 



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A 3/2/57. 

Q And what is your residence address? 

A It's 616 Ninth Avenue Southwest, Puyallup, 

P-U-Y-A-L-L-U-P, Washington 98371. 
Q What -- do you have a business address? 
A No . 

Q What's your residence telephone number? 

A Well, I mostly use my cell phone as my primary contact. 
It's 2 5 3-677-5923. I do have a home phone. That number 
is 253- -- sorry. I never call myself -- 581-4981. 

Q Do you have an e-mail address you use? 

A Yes. It's Call2action, C-A-L-L, number 2, A-C-T-I-O-N at 
MSN.com. And I also use Susan.call2action@gmail.com. 

Q I see you've produced some documents today; is that 
correct ? 

A Yes . 

Q We asked you for all e-mails, correspondence, and written 
communications relating or concerning Plaintiff NXIVM 
Corporation, its predecessors -- its predecessor, 
Executive Success Programs, Inc., Keith Raniere, Nancy 
Salzman, or Clare and Sara Bronfman for the period 
July 9, 2010, to date. 

Did you think that you produced all of that 
material ? 

A I bel ieve so . 



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Q Did you go through your e-mail account? 
A Yes . 

Q And did you print everything there out? 
A Yes . 

Q Did you withhold anything? 
A No , sir . 

Q How about e-mails involving your lawyers? 

A I did not bring any e-mails between myself and my lawyer. 
I believe those are privileged information and that if I 
show you a copy, which you had suggested, that that then 
takes away my privileged confidential information. 

Q I don't think I suggested that at all. I just said bring 
it . 

Did you -- 
A Well -- 

Q What lawyer -- what lawyer are you referring to? 

A Well, the thing is that based on my understanding of the 
e-mail is you said "Bring all. Once I look at them, then 
you can call the judge." And so my belief is, is that -- 

Q No, I didn't say that. 

A Well -- 

Q You have to double-check. 

MR. CROCKETT: Move to strike. 
Q (By Mr. Crockett) What's the -- 

A No, I don't want that stricken. I want that on the 



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record . 

Q Let me just explain stuff. When I move to strike, it's 
nonresponsive . It still is on the record, but what 
happens is, let's say later on we want to read this part 
at trial, then the judge makes a decision whether to 
strike then or not. 

A Right. Well, I just want to make sure that just because 
you suggest that something be stricken from the record 
and that -- for her to take that off, that I don't 
necessarily agree with that. 

Q Well, it's a federal crime for a reporter to actually 
take stuff off the record, so -- 

A Well, I apologize, Mr. Crockett, you know. 

Q No . It's — 

A I'm not an attorney. 

Q Hold it. Stop talking. All right? We're only going to 
do questions and answers here. It's not a lecture. All 
right? All I'm telling -- all I'm trying to do is 
explain to you that when I move to strike, I'm preserving 
an objection on the record. 

A Right. And I -- 

Q Now, the question pending -- 

A And because I don ' t have an attorney -- 

Q Now, Ms. Dones -- 

A Because I don't have an attorney present, I believe that 



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I need to be very careful, and I have a right -- if I had 
an attorney in the room that knew the law, they would -- 
there are certain things that they would object to that I 
don't know whether to object to or not, and I don't 
believe that you have my best interests in mind here. 

Q Ms. Dones, who is the lawyer whose e-mails you're 
withholding? 

A Mr . Tiffany ' s . 

Q Any other lawyers who you believe have advised you in the 

past -- 
A No , sir . 

Q Let me finish the question. 

Just -- there's some, like, ground rules that happen 
in depositions . 
A Okay. 

Q And one of them is -- this is -- this is not like an 
ordinary conversation. You obviously know where my 
question is going, so you -- in ordinary conversation, 
you kind of want to, like, jump in and answer the 
question. That would be okay in conversation but not in 
a deposition. 

A Okay. 

Q I need to finish my question. 
A Okay. 

Q Similarly, I can't jump on you and start talking before 



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you, you know, finish your answer. 
A Okay. 

Q So the question specifically is: Have you had any other 

lawyer helping you with your case since July 9, 2010? 
A No , sir . 

Q Now, last week you filed a declaration with the court 

entitled "Declaration of Susan Faye Dones in Response to 
Plaintiff's Complaint," et cetera. Do you remember doing 
that? 

A Yes , sir . 

Q Do you remember filing it and it wasn't signed? 
A Yes , sir . 

Q And then did you, like, file some follow-up -- 

A Yes , sir . 

Q -- signature? 

All right. Did some lawyer help you file -- prepare 
this declaration? 
A No , sir . 

Q Did you talk to anybody about the contents of that 

declaration to help you prepare it? 
A No , sir . 
Q I mean -- 

A What -- I did do a lot of research. I knew that I needed 
to get this done in order to make the deadline. And 
there was not only the original complaint, but there was 



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an amended complaint which tripled it in size. And in 
that time frame, I had a decision to make whether to do 
the deposition myself to make the deadline or do I take 
some time to try to find an attorney, which I don't even 
know really truly how to go about doing that, especially 
pro bono . 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) The specific question, Ms. Dones, is: 
When you worked on your declaration, did you have other 
people help you with that declaration? 

A Yes, I did. 

Q Who? 

A Joe O'Hara helped me with it. 

Q And did you communicate with him by e-mail about it? 
A No . 

Q So it was all on the telephone? 
A Yes , sir . 

Q But did you send him draft copies? 
A No , sir . 

Q Did anybody else help you with your declaration? 

A I did talk to Toni Natalie about it, and I did talk to 

Barbara Bouchey about it . 
Q How much -- 

A I did send -- I actually -- if I remember correctly, I 



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did send Barbara a copy of it, but I can't remember if I 
sent her any drafts or if I just sent her the final after 
I filed. 

Q Can you show me in your e-mail production where you sent 

her a draft or spoke to her through e-mail about it? 
A I mean, I can look. 
Q Yes. Could you please look. 

A Okay. I'm not even sure if I sent her a final copy or if 
she downloaded it from Pacer. I think she had texted me 
and asked me to, and I was not -- I was taking care of my 
mom, and I wasn't by a computer to send her a copy. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) The question pending is: Is there 

anything in your e-mail production which shows that you 
sent a draft copy of your declaration to Barbara Bouchey? 

A Okay. I'll just look through here. I'm sorry I didn't 
put them in order from that perspective. 
Nope . I don ' t see one . 

Q Did you discuss your draft declaration with anybody else 
other than the persons you've identified to us? 

A No . No , sir . 

Q Did Ms . Bouchey have any hand any drafting any part of 

the declaration? 
A Not directly. Ms. Bouchey has sent me some of her 



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documents that she's used in her court cases, and what I 
did was I used some of that as a guide to go by in 
writing mine . 

Q Did you produce any of those documents that Bouchey sent 
you ? 

A No. No, I didn't. 
Q Why not? 

A I think because I downloaded all of them to my computer. 
Q And so there are some things you've withheld that you've 

kept on your computer; is that correct? 
A No. I didn't withhold any e-mails. A lot of times when 

she would send me stuff, before I knew I was going to 

have to produce e-mails, I just went through and deleted 

e-mails . 

Q So you've been deleting e-mails since your litigation 
started? 

A No, not with NXIVM. I was asked not to do that, and I 
haven ' t . 

Q Can you explain to me why this e-mail is not in your 

production that Ms. Bouchey gave us? 

And I -- the protocol here is that I hand it to the 

reporter . 
A Okay. 

Q She marks it, and then she hands it to you. 
A Okay. 



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MR. CROCKETT: I'll ask the reporter 
to mark this as Dones Exhibit 1. 

(Exhibit No. 1 marked for 
identification. ) 

Q (By Mr. Crockett) Dones Exhibit 1 is an e-mail dated 
October 21, 2010, to Barbara Bouchey from Susan Dones. 
And you can take a look at it, but the question pending 
while you look at it is -- 

A Right. 

Q -- can you explain to me why you didn't produce this 

document in your document production? 
A I don't know, sir. 
Q Did you author this document? 
A Yes, I did. 

Q And is it correct to say that you are basically telling 
Barbara Bouchey in the first paragraph that you were 
willing to lie and swear that you had never sent her a 
copy of this e-mail? 

A Let me just read what -- I don't believe that to be true. 

Q Did you say this: "If NXIVM comes after you, I will sign 
a document that you had no knowledge of this and were not 
included in my e-mail list if they ask who I sent it to"? 
Did you say that? 

A What I -- what -- 



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Q Did you say that? 

A Well, you're taking this out of context. 
Q Did you -- 

A I would like to answer the question. 
Q Did you say that sentence? 

A I did say that sentence, but you're taking it out of 

context, so what I'd like to do is explain that. 
Q The next question I have to ask you -- 
A No . 

Q --is: Who did you send this document to -- 
A No . I am - - 

Q -- other than Ms . Bouchey? 

A -- going to finish answering the question you asked me. 
Q Who did you send this document to other than -- 
A I'm not -- I would like to finish answering this 

question . 
Q There is no question pending. 
A Yes , there is . 
Q What — 

A You asked me if I doctored this, if I said that I would 

lie -- 
Q I didn't — 

A -- and what I would like to do is explain that. 

Q I didn't say -- I didn't ask you if you doctored it. 

THE WITNESS: Would -- could you 



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please read that back then? 
A You asked me if I lied, and I would like to explain. 
Q (By Mr. Crockett) I didn't ask you if you lied. I just 

asked you if you said you would lie in this document. 
A Right. 
Q Now, Ms. -- 

A Right. And I'm -- you know what? I'm not going to 

ask -- answer any more questions until I get to finish 
thi s one . 

Q All right. So let me ask the next question. 
A No. I'm not going to answer -- 

Q That's fine. That's fine. If you -- I'm going to give 
you all of my questions I'm going to ask you today, and 
if you don't want to answer, then you'll -- 

A All right. 

Q -- be in contempt of court, and we'll deal with it. 

A Well, okay. Well, then let's call the judge. 

Q Court is closed today, but if you have his number, go 

ahead . 
A No . 

Q All right. So the next question I have for you -- you're 
certainly more than willing to refuse to answer any of my 
questions I have today. 

A No. I would like to explain this. You asked me if I 

lied about this, and I said, "Please let me read this." 



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Q I -- what question do you think I asked? 

A I would like the court reporter to read it back. 

Q Too long. 

A Please -- 

Q Just say whatever you'd like. 

A Okay. All right. What I meant by saying this is that I 
did not include Barbara in the original e-mail that I 
sent out, and the reason that I didn't send that to her 
is because of her vicarious position in legal battles 
with NXIVM and the Bronfmans . 

And so what I did is I did not include her in this. 
Once it hit the New York Post and then went to the blog 
or whoever got it first -- I don't know -- I believe that 
she had a right to know about this. The thing -- when I 
said "If NXIVM comes after you, I will sign a document 
that you had no knowledge of this and were not included 
in my e-mail," what I meant by that is, is that I would 
sign a document that she was not a part of me sending 
this out to my friends and family. 

Q Now, who did you send Dones Exhibit 1 to other than the 
part that involves Barbara Bouchey? 

A Okay. Let me locate that e-mail. 

Q Well, let me just give it to you from your document 

production, and we'll deal with it that way. 
A Okay. 



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MR. CROCKETT: I'd like the reporter 
to mark the next document as Dones Exhibit 2 . 

(Exhibit No. 2 marked for 
identification. ) 

A Okay. I sent this to Andrew Dallow, Angela Parisotto, 

Angela Ucci, Barb Bell -- 
Q (By Mr. Crockett) Slow. Slow -- 
A Okay. 

Q -- for the reporter. 

A Sorry. -- Betsy Lear, Brenda Renrik, Nina Cowell, 

Chelsie Bowden, Desiree Dones-Stef fens, Elaine Gibson -- 
Q Ellen? 

A Or Ellen. Excuse me. -- Ellen Gibson, Geoff Johnson, 
Jan Heim, Jerie Longacre, Karen O'Brien, Kathy Ethier, 
Katy Fletcher, Kristi Lahusen -- wait. Oops. I'm 
sorry -- Kevin Hlas, Kim Woolhouse, Laura Legere, Lesley 
Bush, Ray Jones, Rob Chiappone, Shelley Vilickoff, Sue 
White, Teri Blubaugh, Toni Foley, Tracy Williams, Yuri 
Plyam, and Joe O'Hara. 

MR. CROCKETT: And, Madame Reporter, 
all of these names are on this document for spelling. 

Q (By Mr. Crockett) Are any of these reporters? 

A No. No, sir, not that -- not that I know of. I don't 
believe any of them are. 



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Q Who is Yuri Plyam? 

A Yuri Plyam is a gentleman in Los Angeles . 
Q How do you know him? 

A I know him -- first, I knew him through my time in NXIVM, 
and I was told that Yuri had stolen millions of dollars 
from the Bronfman sisters. And then after I left NXIVM, 
I realized that I had been lied to about a lot of things, 
and so what I did was I started to go and investigate 
what was the truth and what I believed that I had been 
lied about. So that's how I know Yuri, is meeting Yuri 
and finding out his side of the NXIVM story. 

Q When did you meet Yuri and find out his side of the 
story? 

A It was either -- I think it was in -- as far as I can 

recall, it was in June of 2009. It could have been May, 
but it -- I believe it was in June. 

Q Have you spoken to him recently? 

A Yeah, last night. 

Q Has he told you that the court in Los Angeles has fined 

him over $2 million for lying about documents? 
A No , sir . 

Q What did you talk about last night with Mr. Plyam? 

A He -- I texted him to let him know that I was coming in 

with a deposition with you today without counsel, and he 

just called me to talk to me about that. 



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Q So do you have copies of your texts? 

A No. I don't keep any copies of my texts, except I have 

some from my therapist. 
Q Do you have any copies of your texts to Yuri Plyam? 
A No , sir . 

Q Now, in looking at Dones Exhibit 2 and Dones Exhibit 1 
again, do you have any explanation as to why you didn't 
produce to me Dones Exhibit 1? 

A I don't have any explanation. It could have been an 
oversight . 

Q So it ' s your testimony you didn't intentionally destroy 

Dones Exhibit 1 -- 
A No , sir . 

Q -- before -- is it your testimony that you did not 

destroy Exhibit -- Dones Exhibit 1 before coming here 
today? 

A No , sir . 

Q What is your testimony? 

A That I did not destroy it. 

Q Dones Exhibit 1 indicates that you're circulating a video 
link on YouTube to somebody, to the recipients of this 
e-mail . What video link were you circulating? 

A I'm not sure what you mean by that. 

Q Take a look at Dones Exhibit 1. And the second page, 
"This video is intended for you only, and I trust you 



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will keep its location safe. Here is the link." 
A Yes . 

Q And then there's a YouTube location. 
A Right. 

Q What video was that? 

A That was the video that I sent out for my safety in 
regards to my concerns about Keith Raniere ' s what I 
believe is escalating behavior. 

Q And where did you get that video? 

A I taped that video in a meeting, three days of -- well, 

actually, I was only there for two days of a meeting with 
Keith Raniere. That video was agreed to be taped by all 
ten members that were there the first day. There were 
five people at that meeting the second day and only three 
people there the third day. It was agreed by all ten of 
us that it would be filmed, that it would be filmed with 
my camera. And my understanding of the law that anything 
that's filmed with my camera becomes my property. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) I'm not asking for your justifications 
and things like that. I'm just asking you what the video 
was about . 

A I'm sorry, sir. It was three days of meetings with Keith 
Raniere. It was nine women who had concerns about his 



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behavior, and so those meetings were designed to confront 

him about our concerns . 
Q Did you -- and did you videotape all three days? 
A I videotaped the first two days . The third day was 

videotaped by my partner, Kim Woolhouse. She set up my 

camera . 

Q Were you a NXIVM -- did you have a title at NXIVM at the 

time that you videotaped this? 
A I had several titles . 

Q And at the time you videotaped that tape, what were your 
titles ? 

A I was a center owner of the Tacoma center; I was a field 

trainer; I was a proctor; and I instructed Ethos classes. 
Q Were you a -- 

A And I was also a salesperson. 
Q And were you a head trainer? 
A Not at that time . 
Q But you'd been a head trainer? 
A For a short period of time. 

Q Now, have you seen the entire videotape for the first day 

in which you were not there? 
A Not in a long time . 

Q Did you realize that there was an agreement on the video 
between Keith Raniere and all present there that the 
contents of the tapes would be kept confidential? 



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A My understanding is, is that we agreed to that, but we 
never agreed to it under the guides of any NXIVM 
confidentiality agreement. 

Q So in this video that persisted for three days, did you 
talk about problems with the NXIVM organization? 

A We talked about problems about how his behavior -- his 
personal behavior we believed was affecting the company 
and destroying the company. 

Q Okay. So I realize the video speaks for itself, but -- 
and I won't hold you to everything that's in it, but -- 
so among one of the things you talked about was his 
behavior and how it affected the company; is that 
correct ? 

A Yes . 

Q Did you talk about ways to make the company better? 
A I don't recall that. 

Q Did you talk about ways he could change his -- the way he 
ran things so the company would be better? 

A I don't recall that. I remember talking about his -- how 
his behavior was affecting the company and that -- my 
assumption is, is that if he would change, then the 
company could change with that. 

Q Did you have discussions about the way commissions were 
being paid? 

A Not that I recall . 



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Q Did you talk about the way there -- people were being 

favored one over another? 
A I don't recall that either. I haven't watched the videos 

in a really extremely long time. 
Q And so the videos went on for three days, but the only 

thing you can recall today about them was that you were 

concerned about Keith's behavior as it related to the 

company? 
A (Witness nods head.) 

Well, I recall some other things, but that's what I 

recall in regards to the questions you've asked me. 
Q What other things do you recall? 

A I recall becoming -- that I got really upset because I 
didn't believe by the second day that -- I felt like he 
was just chasing us around what I would call the mulberry 
bush, and I feared that based on his behavior, that if he 
chose not to take a look at it that I could no longer 
participate in the company. 

Q And how many minutes were on the link that you sent out 
to your friends in Dones Exhibit 1 and 2? 

A I don't recall that. I would say -- do you want me to 
guess ? 

Q Estimate . 

A Estimate, I would say maybe six or seven minutes. 

Q And what portion of the videotape did you single out for 



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putting on YouTube? 

A The only -- the only thing that I did put on YouTube, 
which is under a private link -- the only way anybody 
would know about that is to have that link. It's not 
like it is a public video -- is the part where Keith 
Raniere mentions that people have died for his beliefs 
and that he has had people killed for his beliefs. 

Q And so everybody on that e-mail list got that link; 
correct ? 

A Correct . 

Q And did you know at the time when he was talking about 
people dying for him and people being killed for him 
related to the documentary that was being filmed in 
Mexico ? 

A My understanding -- I didn ' t know about -- I knew about 

the documentary in Mexico. I'd never seen that, but when 
he said "I have had people killed for my beliefs," that 
scared me . 

Q Well, you were there when he said that; correct? 
A No, I wasn't at that meeting. 

Q All right. Did you know that when Mr. Raniere stated 
that people -- that he had people killed because of his 
beliefs that he was talking about the consequences of a 
documentary that was filmed in Mexico when a member of 
the LeBaron family was killed by drug lords in the middle 



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of the documentary by Mark Vicente? 
A No , sir . 

Q No. Have you ever -- did you know that Mark Vicente was 
filming a documentary of the LeBaron family in Mexico? 

A I knew he was filming a documentary. I didn't know what 
it was about . 

Q Did you know Benjamin LeBaron was murdered by cartel 

members in the middle of the documentary? 
A No , sir . 

Q Did you know that the documentary documents Keith's 

apparent advice to the family to avoid paying ransom? 
A No , sir . 

Q And did you know that the documentary says that the 
family decided not to pay ransom and their son was 
released, and then the father was killed for not paying 
ransom? 

A No , sir . 

Q You've never heard Keith say something like "And I feel 
like I'm responsible for that. I've had people killed 
for my beliefs"? 

A No, sir. I spent very little time with Keith in my time 
in NXIVM. 

Q So what -- 

A Mark -- and I also spent very little time with Mark 
Vicente , so . . . 



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Q Why did you feel like you wanted to post that -- did 

you -- let me back up. 

Did you talk to Barbara Bouchey about what she 

thought that Keith meant when he was saying that "people 

were killed because of me"? 
A We talked about it when we first watched the video, 

after -- the evening that that video was taped and I 

stopped the video three times because I was scared. And 

I said, "Did you hear what he said?" 

And she said that she didn't believe that Keith had 

had people killed. 
Q And did Barbara Bouchey ever tell you in any of these 

conversations that what Keith's talking about is the fact 

that Benjamin LeBaron was murdered in the middle of the 

filming of a documentary in Mexico? 
A No , sir . 

Q So she -- is it correct to say that Barbara Bouchey 

didn't even mention the Mexican documentary at all to 
you ? 

A Not that I recall . 
Q Ever? 

A Ever. The only -- the only person I ever heard about a 
documentary from was Mark's ex-girlfriend, Kristi 
Lahusen . 

Q Well, I'm not talking about that. 



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A That's the only place I ever heard about the video -- 
Q All right. So -- 
A -- was from her. 

Q So my -- my specific question is: Before you posted the 
link where Keith supposedly boasted about having people 
murdered, did you tell Barbara Bouchey that you were 
going to make that link -- you were going to make that a 
YouTube link before you did it? 

A No , sir . 

Q Then after you sent this e-mail that's Dones Exhibit 1, 

did Barbara Bouchey call you and say, "You've just got it 
wrong. That reference that Keith made was to the 
documentary in Mexico"? 

A No, sir. She never called me and talked to me about 
that . 

Q Do you -- what are all of the titles that you've held in 
NXIVM? 

A I think I've answered that. Do you want me to repeat? 

Q Well, they kind of fragmented because we were talking 
about the titles at the time of this e-mail. And I'd 
like to give you -- have you just tell me all titles -- 

A Okay. 

Q -- from start to finish. 

A I was a center owner, which is different than what NXIVM 
claims in their -- they call me a center head at this 



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particular -- in their filings. I was a field trainer. 
I was a salesperson, and I was an instructor of Ethos 
classes. And for a short period of time, I had been a 
head trainer . 

Q And so a center owner means that you would own a 

particular center in Tacoma, Washington; is that correct? 

A What a center owner means is that the person ponies up 
the money to open the center until the center becomes a 
chartered center. And so what I did was I paid for all 
of the rents, all the TVs, all the DVD players, all of 
the chairs, copies of the notes, all of those different 
things. And then when we reached 100 Ethos students in 
the center, then the center became chartered. And at 
that point, from that point on, I received 10 percent of 
the sales that took place in that center. 

Q Did you ever become chartered? 

A Yes . 

Q So is it correct to say that your center was one of the 
more successful centers in the NXIVM organization while 
you were running it? 

A I don't know if it was one of the more successful 

centers. I think that the centers in Mexico actually 
produced more income than my center did. And there were 
only four centers: New York, mine, Mexico City, and 
Monterey . 



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Q Now, who was the owner of the center? Was it you or the 

name of some company? 
A It was the -- well, the checks were written to Global 

Solutions, which was my corporation before I entered into 

NXIVM, and I just incorporated that into my business. 
Q Okay. So did the center, like, have a lease? Did it pay 

for space? 

A The center did -- did -- well, we originally opened the 
center in Federal Way, Washington, and then when that 
building no longer was available for us, then we actually 
didn't have a space for a while. And then from that 
point, then a couple of people got together and said, 
"Why don't you guys buy a building?" 

So three of us came together -- actually, there was 
four of us came together, and we bought a building and 
then leased it . 

Q And did you buy the building in the name of Global 
Solutions ? 

A No , sir . 

Q Okay. Whose name did you buy it in? 
A Just personal people's. 

Q Okay. So now, did money go from NXIVM to the center 
somehow ? 

A What happened is, is that in all applications that were 
charged, the applications went from whoever the field 



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trainer was to NXIVM. NXIVM charged 100 percent of that 
tuition, and then the following month they would divvy up 
the percentage to the field trainer, salesperson, 
proctors. You know, if it was a training, head trainers 
got a percentage of that, and then the centers got a 
percentage of their money. 

Q Now, did NXIVM send money then to Global Solutions? 

A Yes . 

Q Did NXIVM send money to you? 
A No , sir . 

Q So then it would have made no sense, correct, to complain 

about a W-2 or 1099 because it was a corporate 

relationship; correct? 
A Well, my understanding is, is that when you pay anybody 

over $600 a year that that entity gets a 1099. 
Q You think that your understanding pertains to a 

corporation ? 
A I don't know corporate law. 

Q Okay. So how many total students do you think -- is 

students the right word or is it clients? 
A I think they refer to them as students or members . They 

use those two words interchangeably. 
Q All right. How many total students went through your 

organization while you were the owner or the head of the 

organization ? 



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A I have no idea . 
Q Dozens? 
A Yes . 

Q More than 100? 
A Yes . 

Q More than 200? 
A Yes . 

Q More than 500? 
A I believe so . 

Q And can you bracket for me the years in which you were 
running the Tacoma center? 

A Just in Tacoma or the one in Federal Way. 

Q And Federal Way as well, back at that time. 

A You know, I'm not sure when we opened. Yeah. I don't 
know our start date. 2003, 2004. It was during the 
summer, but I don't know for sure what year. It could 
have been 2005. I don't really know that. And then 
we -- then I closed in April of 2009. 

Q So approximately four years you were running the Tacoma 
center ? 

A At the -- at the actual Tacoma place -- 
Q Yes . 

A -- where we incorporated -- 

Q And Federal Way, Federal Way and Tacoma. 

A It could have been -- it might have been a little bit 



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longer. Five -- five years. 

Q Was there somebody higher than you in the organization 
locally here, or was it always you in charge? 

A Well, I was -- no. I was the center owner. So there 
were six proctors originally in the -- I mean not 
originally, but we developed into six proctors. One 
eventually moved to New York, but the proctor group ran 
the center from that perspective. I was just the one who 
was in charge of the finances. 

Q Now, when you interacted with the students or the 

members, did you reguire them to sign confidentiality 
agreements ? 

A NXIVM reguired them to sign confidentiality agreements. 
Q Did you collect those from the students yourself? 
A Not -- not always . 
Q But usually? 

A No, not usually. Usually another staff member collected 
those . 

Q But they were working under your direction; correct? 
A Correct. Well, they were working under direction of all 
of us . 

Q All right. And those confidentiality agreements, did 

they have a name, like long form? 
A I think they were just called confidentiality agreements. 
Q How many pages were they? 



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A They varied. I think they were six to eight pages. 

Q And then the students or the members, when they signed up 
for an intensive, they would sign an application with a 
confidentiality agreement on the back; correct? 

A When they signed up for any program. It was actually 

the -- I think that disclaimer was actually on the front 
of the application and then continued onto the back of 
it . 

Q Let me show you what I'd like the reporter to mark as 
Exhibit Dones 3. And I apologize for the copy, but 
photocopying sometimes doesn't work the way it should. 

A Yeah. I'm wondering if after this we could take a break. 

Q Oh, sure. Right after the -- let me ask you a couple 
questions -- 

A Sure . 

Q -- about this, and we'll take -- 
A Sure . 

Q --a short break. 

(Exhibit No. 3 marked for 
identification. ) 

Q (By Mr. Crockett) Exhibit Dones 3 is an intensive 

program application apparently signed by Susan Dones 
sometime in '08. It's two pages, and the question is for 
you: Have you ever seen this document before? 



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A It's really hard to read the writing on it, but I would 

assume I have just based on what I can make out of it. 
Q That kind of looks like your signature? 
A I can't even really read the signature. 
Q It says Susan Dones, though; right? 
A Right. 

Q And up at the top it says Susan Dones? 
A Yes . 

Q Is this something you would have signed? 
A Yes. I signed several of these. 
Q All right. Do you want to take a break? 
A If we could. 

Q Yeah. How much time would you like? 

A I just need to run to the ladies' room. 

Q Sure . 

A Just maybe -- 

Q Absolutely. 

A -- five, ten minutes. Would that be -- 
Q Sure. Uh-huh. Yep. 

THE VIDEOGRAPHER : With permission of 

counsel then and those present, we'll go off the record. 

The time is 11:18. 

(Recess 11:18 - 11:23 a.m.) 
THE VIDEOGRAPHER: Okay. We're back 



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on the record, and the time is 11:23. Please proceed. 

MR. CROCKETT: And the next document 
I'd like the reporter to mark is Dones Exhibit -- 

THE WITNESS: 4. 
MR. CROCKETT: -- 4. 

(Exhibit No. 4 marked for 
identification. ) 

Q (By Mr. Crockett) Dones Exhibit 4 is another intensive 
program application, but this one is dated in '06. It 
appears to have your signature. 

Does this look like something you signed? 

A Yes . 

Q Now, these intensive program applications have a 
statement on the back that refer to methods and 
material -- 

A Mm-hm. 

Q -- being acquired at great time and expense and 
proprietary and confidential. Do you see that? 
A Mm-hm. 
Q It --yes? 
A Yes . I'm sorry . 

Q As part of your duties in Tacoma and Federal Way, did you 
try and let the members and students know that ESP and 
NXIVM's materials were confidential? 



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A I don't believe that I tried to let them know. I think 

that this and the confidentiality agreement spoke for 
itself . 

MR. CROCKETT: All right. The next 

document I'd like to have marked is Dones Exhibit 5. 

(Exhibit No. 5 marked for 
identification. ) 

Q (By Mr. Crockett) Dones 5 is a document entitled "12 

Point Mission Statement by Keith Raniere . " Have you ever 
seen this document before? 

A Yes . 

Q Was this recited at the intensives? 

A It was recited before any NXIVM -- official NXIVM class. 
Q Every time? 
A I believe so . 

Q And did you sometimes lead that recitation yourself? 
A Yes . 

Q And I note that in the middle of the page it says, "The 
methods and information I learn in ESP are for my own 
use" -- or "my use only. I will not speak of them or in 
any way give others knowledge of them outside ESP. Part 
of the condition of being accepted into ESP is to keep 
all of its" -- "all its information confidential. If I 
violate this, I am breaking a promise and breaching my 



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contract, but more importantly, I am compromising my 
inner honesty and integrity." 
Do you see that? 

A Yes . 

Q That's one of the things that was recited? 
A Yes . 

Q Now, did you think that ESP and later NXIVM, did they -- 
were they obsessed with secrecy or something? 

A That -- I mean, that would cause me to speculate if they 
were . 

Q Did it appear to you that -- did it appear to you that 

NXIVM was obsessed with secrecy? 
A I don't know if obsessed is a good word. I believe that, 

you know, it was important for them to keep their 

materials confidential . 
Q Why? 

A Because they're their materials. 

Q People paid a lot of money for them; right? 

A Correct . 

Q These were not cheap courses; correct? 
A Correct . 

Q They cost many thousands of dollars; right? 
A Yes . 

Q And the members / student s would receive materials that 
NXIVM considered confidential; correct? 



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A Correct . 

Q And then the trainers and the proctors themselves would 

have materials that were confidential? 
A And coaches, too. 
Q And coaches, too? 
A Yes . 

Q So coaches and trainers, they all received confidential 

materials; correct? 
A Correct . 

Q And this was, like, written material? 
A Yes, there's written material. 

Q And is it correct to say that every NXIVM meeting -- 

almost every NXIVM meeting is videotaped? 
A In New York, it is. 
Q Is it videotaped in other places? 

A During trainings, during intensive trainings, they film 
in other areas. During our normal, like, Ethos classes, 
coach meetings, that kind of stuff, we didn't film any of 
that . 

Q But they were filmed in New York, the coaches' classes? 

A Yes. Well, you know, I take that back. I don't think 
Ethos was filmed, and I don't believe a lot of stuff was 
filmed. Usually, if Nancy was there, it was filmed. 

Q Or if Keith was there, it was filmed? 

A Yes . 



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Q Now, the -- were you ever told the reason why this 

videotaping was done? 
A For historical perspective. 

Q Were you also told that one reason the videotaping was 
done was that -- so that the course designers, the 
proctors, or Nancy Salzman could go back and look at the 
tapes to make sure that the teaching and course material 
was consistent? 

A Can you ask me that again? I'm sorry. 

Q Yes . 

MR. CROCKETT: Madame Reporter -- 

A It was a lot of -- 

Q (By Mr. Crockett) Yeah. 

MR. CROCKETT: Madame reporter, could 
you read the question. 

(Question on Page 40, Lines 4 
through 8, read by the 
reporter . ) 

A I don't believe I was ever told that. 

Q (By Mr. Crockett) Were you told that the videotaping was 
done in part so that Keith or Nancy could go back and 
look at the material to resolve problems? 

A I don't believe that I was ever told that they could look 
at it to go back and resolve problems. 



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Q Was the videotaping ever done by an outsider, like a 

nonNXIVM person? 
A The only thing that I know in regards to that is that 

those things were -- when they did the videos at first, 

the DVDs that we have in class, that they hired outside 

people to come in and do those. 
Q Did they often have coaches or other NXIVM officers film 

the proceedings themselves? 
A They did, yeah. 

Q Now, the videotape -- the three-day videotape that you 

participated in with the other women and with Keith, were 
copies given to Keith? 

A I believe that -- I gave Barbara Bouchey a copy on a hard 
drive that she gave to her attorney at the time . I don ' t 
remember his first name, but his last name was Green, 
not -- the one in New York, New York. 

Q Ford Greene? 

A No. Ford Greene is in California. She had another 

attorney -- 
Q Oh, Pat Green. 

A Pat Green. And without Barbara's permission, Pat gave a 
copy of that to Keith and Nancy -- or to -- gave it to 
Steve Coffey, I think. 

Q The next document I'd like to have marked is -- excuse 
me. I'm going to have to collate. I'm not doing this 



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right. Excuse me. 

All right. The next document I'd like to have the 
reporter mark is Dones Exhibit 6. 

(Exhibit No. 6 marked for 
identification. ) 

Q (By Mr. Crockett) Dones Exhibit 6 is a confidentiality 
agreement which apparently bears her signature on the 
back. Well, I'll ask you about that. 
Did you sign Dones Exhibit 6? 

A This -- that, I don't know, if this is one that I signed. 

Q But you -- did you sign a document like this? 

A I don't know if it was exactly like this. What I 

remember is, is that the confidentiality agreement was 
shorter and that there was no typing at the top, that we 
wrote in our own dates, and that -- this part right here 
where it has the companies was in a different format. 

Q And is that your signature on the last page? 

A It looks similar to my signature, but I'm not sure it's 
mine . 

Q And is there any content -- 

A And the printing below, where it says "print name" -- 
Q Right. 

A -- does not look like my printing. 

Q But the signature part of yours looks like yours, but 



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you're not certain if it is yours? 
A Correct . 

Q And the document -- the internal parts of the document, 
is there anything in the document itself which you don't 
ever recall signing or agreeing to? 

A You know, I don't remember the confidentiality agreement. 
When I left NXIVM, I asked to be provided a copy of my 
confidentiality agreement, and I was refused that by 
Pamela -- it was one of -- the firm that Steve Coffey 
works at, they refused to provide me one without a court 
order . 

Q This -- but the confidentiality agreements, these longer 
form confidentiality agreements, you handled -- or you or 
your staff handled on a routine basis in Tacoma; correct? 

A Correct . 

Q And is this document that is Dones Exhibit 6 different in 
any respect than you recall those agreements that you 
handled with your course members? 

A Well, the format -- the format is different, and that's 
what brings it into question. And then I'm not sure if 
that's my signature, and that's what brings it into 
question. And then in between -- from the last page, 
Page -- oops. There's only five of these pages. 

So on Page 5 -- there's supposed to be 5 of 7. On 
Page 1 through -- 1 through 4 has no signatures, no 



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places for initials, and so the content of this could be 

changed at any time. I know they've changed the 

confidentiality agreement several times. 
Q Do you believe that you're not bound by a long form 

confidentiality agreement? 
A I believe I am bound by it if this is, indeed, my 

confidentiality agreement and that is, indeed, my 

signature . 

Q Do you believe that you were coerced into signing the 
long form confidentiality agreement? 

A I believe that I was coerced due to the fact that this 
was given to me -- if this is indeed mine, this was 
handed to me the day I showed up for class in Albany, New 
York. I had flown the day after Christmas to go to New 
York. I had no time to read it and really no time to run 
it by an attorney, and so it was either sign it or go 
home. And so I believe that that in itself is coercion. 

Q Now, when you persuaded members and students in the 
Tacoma facility to sign the equivalent of Dones 
Exhibit 6, do you believe you were coercing them? 

A I don't believe that I ever persuaded anybody to sign it. 
If they had questions about it, then I tried to sit down, 
and if they believed that there was something in here 
that they didn't understand, then I suggested that they 
take the time to find that out . 



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Q But you remember in Tacoma with dozens or hundreds of 

students that you would ask them to sign the equivalent 
of Dones Exhibit 6? 

A Well, the thing that we did at our center is this was 
sent out in a welcome packet. So the student had this 
copy -- or not this particular copy or the style, but 
they had this several days, several weeks before they 
ever came to the course. And so they had plenty of time 
to review it and, if they had questions, to run it 
through an attorney. 

Q And at any time did any member or student in the Tacoma 
facility complain that they were being coerced into 
signing the long form confidentiality agreement that 
looks like Dones Exhibit 6? 

A Not that I recall. 

Q And when you signed -- 

A But several students -- several students in Albany, New 

York, believed that they were coerced into signing it. 
Q Well -- 

A As a matter of fact, several people I went to class with 
were upset by the fact that we were handed this the 
morning of with no time to really review it. 

Q Well, I guess I'm asking you about your practice here in 
Tacoma. Did any student ever come to you and say, "You 
know, Ms. Dones, I'm upset. You've coerced me into 



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signing the long form confidentiality agreement"? 

A The only person I had come, they were concerned about the 
section where it talks about that they -- that -- let me 
find it. It might not even be in this one. 

I don't see it in here, but it was about -- their 
guestion was, is that in regard -- and it might be in 
here; I'm just missing it -- where they talk about the 
personal use once they leave. And their guestion was, 
"If I've integrated the information, how could I not use 
that in my daily life, you know?" 

Meaning, like, if you study something, how can you 
not integrate that? 

Q Other than that complaint, did you ever hear any of your 
students or members in the Tacoma facility complain about 
having to sign the long form confidentiality agreement? 

A No, not at my center. 

Q What would you do with the forms once they were signed? 

A Our -- at first our standard practice was to take the 
forms and put them in their student files, which we 
stored at our center. And then what happened is, is that 
there was a period of time between 2000 and 2003 where a 
lot of confidentiality agreements were lost. And then 
what happened was, is that NXIVM started to reguire that 
we -- when somebody flew back to New York, is that they 
would bring a packet of confidentiality forms back to New 



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York. And that was our standard practice, is to send 

them back to New York. 
Q So did you ever fly back to New York with a packet of 

confidentiality agreements to give to NXIVM? 
A I don't believe I ever carried any confidentiality 

agreements to give them. 
Q Did you have a member of your staff do that? 
A It's not like I asked somebody to do that. I didn't 

really have a staff, I mean, but I believe that there 

were proctors and coaches who took stuff back with them. 
Q From Tacoma? 

A Yes . And I think the person that was in charge of that 
particular project was either Wendy Rosen-Brooks or 
Charmel Bowden . 

Q Now, did you sign more than one long form confidentiality 

agreement ? 
A Not that I recall. 

Q So having said that you were coerced, did you ever 

complain right shortly afterwards that you were coerced 
into signing the confidentiality agreement? 

A I did -- I did at that particular time. I said that 

"You're asking me to sign something that I haven't had 
time to review. If I review it, I have no time -- if I 
have questions, I have no time to ask an attorney about 
what I'm signing." 



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And then I asked if I could get once all the 
signatures were on, my witness, whoever witnessed it -- 
and then there was a spot on here that ' s not included in 
this one where Keith -- Keith and Nancy sign it. And 
what I did is I reguested several times during that 
16-day training to receive a copy of this confidentiality 
form or said confidentiality form back with all of the 
signatures. And then again when I left, I asked for a 
copy of the confidentiality form. 

Between the time I started and the time I left after 
that, I never paid much attention to the confidentiality 
agreement . 
Q But you -- 

A I sent it out like I was instructed to. 

Q Is it correct to say that you signed the eguivalent of 
Dones Exhibit 6 even though you were concerned about 
coercion ? 

A I did because I had a huge investment in getting there. 
Q And — 

A It was either -- it was either sign it or go home. 

Q And did you understand as you continued to take training 
from NXIVM and receive their course materials that NXIVM 
considered everything there to be confidential? Correct? 

A I believe that they considered their course material 
confidential. I didn't believe that that meant 



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personal -- our professional behavior was confidential. 
Q Did you believe that they considered the videotapes 

confidential? 
A I believe that they considered their videotapes 

confidential. I don't believe that that includes the 

videos that I did. 
Q And where did you film that video? 
A The video was -- 

Q Let me rephrase the question. The video we're talking 

about is the three-day video that you said you taped or 

somebody else taped the first day of. 
A Yeah. NXIVM refers to them -- just if we can simplify 

it -- refers to it in their complaint against me as the 

April 20 9 meetings. 
Q Okay. The April 2009 meetings, where did this -- where 

did these meetings take place? 
A They were at a building that was purchased -- I believed 

at that particular time that Barbara Bouchey had 

purchased that building, and it was to be turned into a 

24-hour internet cafe. 
Q And what was the address of that? 

A I don't -- it's on Route 9. That's all I know. It's the 

old Romano's restaurant. 
Q The restaurant. That's correct. And do you understand 

that restaurant today to be a NXIVM facility? 



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A No, I don't understand that, nor do I believe it was a 

NXIVM facility. I believe that -- my understanding from 
my experience being there is that when the building was 
rehabbed and -- the first event that took place in there 
was Nancy's birthday party, but my understanding that the 
Half Moon town council was never told that that was going 
to be a NXIVM facility, nor was it owned by NXIVM. 

Q Do you have any reason to believe that it's owned by 
Barbara Bouchey? 

A Just stuff that I've read that originally she had bought 
it, and it's in those town council meeting notes. 

Q And did NXIVM gatherings occur there? 

A NXIVM gatherings have occurred there, but my 

understanding is, is that's not the -- that's not the 
purpose of that building based on what they went into the 
town of Half Moon. They said that that building was not 
going to be a private facility, that NXIVM classes were 
not going to be taught there, that that was going to be a 
24-hour internet cafe open to the public. 

Q And has it ever been open to the public as an internet 
cafe? 

A Not that I'm aware of. 

Q Has it ever been used for any public purpose after it was 

purchased by Bouchey or whomever? 
A That, I don't know. 



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Q So as far as you could tell and as far as you saw, the 

only things that occurred in that building were 

NXIVM-related matters? 
A No . I think that there have been some other matters that 

have taken place there, private parties, that kind of 

stuff . 

Q Did you ever witness those? 
A Well, Nancy's birthday party. 
Q Okay. Nancy, the president -- 
A That ' s the only -- 

Q -- of NXIVM's birthday party was there? 

A That's the only time I was ever in the facility other 
than the meetings . 

Q Okay. Have you ever seen anything other than a 

NXIVM-related activity occur at that building other than 
your meetings there and Nancy Salzman's birthday party? 

A That's the only thing that I've seen happen there. So 

other than that, whatever has happened there -- I believe 
that there's been Halloween parties just from stuff that 
I've read on the internet, but I understand that that's 
not the reason why that building was approved to be 
turned into the facility it was. It was designed to be 
an internet cafe open 24 hours to the public, and as far 
as I'm concerned, that's still the zoning for that 
bui lding . 



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MR. CROCKETT: Move to strike as 

nonresponsive. 
Q (By Mr. Crockett) Have you ever seen it used as a 
24-hour cafe? 

A I haven ' t been to New York in years . So as far as I 

know, it hasn't been, but I don't know any activities 

there since I left. 
Q Do you think that NXIVM lacks standing to seek an 

injunction against you for violation of the 

confidentiality agreement? 
A Well, they haven't -- you guys haven't even gotten into 

what they believe I have violated. 
Q No. I think my question is: Do you think NXIVM has 

standing ? 
A No, I don't. 
Q And what's that based on? 

A That I haven't violated their -- I haven't disseminated 
their information, their materials. They accused me of 
teaching classes after I left NXIVM. That's not true. 

Q Isn't it correct to say that your standing theory is 
based upon the fact that you don ' t think that NXIVM 
really owns Rational Inquiry? 

A I don't know -- I think -- my understanding of Rational 
Inquiry is, is that Keith Raniere owns Rational Inquiry 
and then leased that to Nancy Salzman, based on just 



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conversations that I've had with Nancy. 
Q Nancy Salzman being the president of NXIVM; correct? 
A Correct . 
Q All right. 

A And the owner of NXIVM, from my understanding, and the 
owner of First Principles, which licenses -- from my 
understanding, it licenses Rational Inguiry. 

Q Do you have any firsthand knowledge to say that Pamela 
Cafritz was a -- one of Raniere ' s girlfriends? 

A Have I ever seen them together? 

Q Yes . 

A No . 

Q Who told you that Pamela Cafritz was one of Raniere ' s 

girlfriends ? 
A Barbara Bouchey. 
Q Do you have any first -- 
A And Toni Natalie. 

Q And these are former Raniere girlfriends themselves; 
correct ? 

A I don't have any firsthand knowledge of that either. 
Q But you believe that to be true? 
A I believe that to be true. 

Q Do you have any firsthand knowledge that Pamela Cafritz 

was a former partner of Keith Raniere? 
A Yes, in CBI . 



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Q How do you know that? 

A From Toni Natalie and then also the court document where 
the judge ruled against -- I think it was actually the 
attorney general of the state of New York at that 
particular time sanctioned all three of them. 

Q Do you believe that Pamela Cafritz is highly skilled at 
forging signatures? 

A That's what I was told by Nancy Salzman and Pamela 
Cafritz . 

Q Pamela Cafritz told you she was highly skilled at forging 

signatures ? 
A She bragged about that to me . 
Q Do you -- 

A And then I also did some more research on that, and I 

have found that other people have actually witnessed her 
doing that . 

Q Who? 

A Toni Natalie, Toni Natalie's mother, and then Barbara 

Bouchey also said that she knew that Pam was -- had that 
capacity . 

Q Okay. So these are all former girlfriends of Keith 

Raniere who claimed that Pamela Cafritz was a forger; 
correct ? 

A I don't believe Toni Natalie's mother was a former 
girlfriend . 



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Q Right. Did Toni Natalie's mother ever tell you that she 

had seen Cafritz forging signatures? 
A I haven't talked to her personally. 

Q Now, so Pamela Cafritz told you specifically that she was 
a forger? 

A She told me that she was skilled at doing that. 

Q And what kind of signatures did she say she forged? 

A She didn't say that, that she -- she didn't go into 

specifics about what types of signatures she had forged. 
Q Did she say she had forged any NXIVM-related documents? 
A No . 

Q Did she say she had forged any government documents? 
A Not to my knowledge . 

Q Did she say she had ever forged your signature? 
A No . 

Q Do you have any reason to believe that she ever forged 

your signature? 
A I -- yes , I do . 
Q What? 

A Because of the fact that a group of these confidentiality 
forms were missing. I was told that by Nancy Salzman, 
that they had lost a lot of confidentiality agreements 
between 2000 and 2003. 

Q So you believe that you're bound by the confidentiality 
agreement, but nonetheless, you think your signature has 



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been forged to it? Is that what you're saying? 
A Well, I believe I am bound by a confidentiality 

agreement, and if that is produced with my original 

signature on it, then I believe I'm bound by that 

confidentiality agreement. 
Q You state in your declaration: "NXIVM claims to be a 

corporation that offers various training programs and 

courses to advance human potential and ethics through 

personal and professional development." 

Is that an accurate statement? Does NXIVM really 

claim that? 

A I believe that they -- that's what they claimed in my -- 

their complaint against me. 
Q So you're just repeating what they're claiming against 

you ? 

A Well, it's also on their website, if you go to their 
website . 

Q Do you believe that NXIVM has a twisted view of ethics? 

A I do . 

Q And how so? 

A Because they teach ethics, but in my opinion, a lot of 
things that they teach are not moral. And then they'll 
say one thing -- they'll teach one thing, and then their 
behavior shows a completely different thing. 

Q Let's deal with what they teach. How -- what do they 



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teach that's twisted? 
A Well, one of the things that they talk about is on -- in 
their material is they talk about why do we pay taxes. I 
believe paying taxes is a good thing. It's a responsible 
thing to do . 

Q Have you ever seen any written course material from NXIVM 

saying, "Don't pay taxes"? 
A Not any written, but on one of the videos, if I remember 

correctly, Nancy Salzman talks about the taxes and not 

paying taxes and things like that. 
Q Well, let's focus on the written materials. Have you 

ever seen any written materials handed out to students 

advocating nonpayment of taxes? 
A No, no written materials. 

Q Other than on some video talking about not paying taxes, 
how -- what other teaching method has NXIVM employed that 
involves a twisted view of ethics? 

A Well, one of the things that they teach us is that 
relationships are -- come from a place of inner 
deficiency, in that if somebody is in a marriage that 
that is just a place of fulfilling your inner 
deficiencies. And so I believe that NXIVM teaches that a 
marriage, a primary relationship, is not a good thing to 
have . 

Q Have you ever seen any written course materials from 



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NXIVM saying that a marriage is not a good thing to have? 
A Not any written materials . Although -- let me take that 

back. Let me think. 

I think in their relationship module -- and again, I 

would have to go back and review that, but in their 

relationship module, they talk about relationships coming 

from a place of inner deficiency. 
Q Isn't it correct that NXIVM teaches that its coursework 

can help improve marriage relationships? 
A I don't believe that they teach that. 
Q Have you ever seen anything in writing from NXIVM 

advocating the destruction or dissolution of marriage? 
A Well, I believe that something in writing versus 

something that is told is completely two different 

things . 

Q No. My question is: Have you ever seen anything in 
writing? 

A I would have to go back and review the relationship 
modules . 

Q As you recall today, have you ever seen anything in 
writing saying that NXIVM believes that marriage is 
something you shouldn't be involved in? 

A I believe that that's possible. I would have to go back 
and review. 

Q You can't think of anything specific today; correct? 



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A It's been a long time since I've looked at their 
materials . 

Q What other anecdotes can you give me in terms of -- I 

want written course material where you believe NXIVM has 

a twisted view of ethics. 
A And again, I apologize. I have not looked at any of 

their written materials since I left, so I can't refer to 

anything right off the top of my head. 
Q All right. But you believe that certainly their behavior 

is inconsistent with their ethics; correct? 
A Correct . 

Q How is their -- whose behavior is inconsistent with their 
ethics ? 

A Well, I believe that a lot of the upper leadership, one 
being Nancy Salzman. Like in the case of the Washington 
State Department of Revenue, when that thing came about, 
she called me. She asked me if I paid by B&O taxes, and 
I said, "Of course I pay my B&O taxes." And I said, 
"Why? Why are you even asking?" 

She said, "We're having a problem with the state 
department of revenue, and I wanted to make sure that you 
paid your B&O taxes before we dealt with this because we 
didn't want to get you in trouble." 

And I said, "Well, what's going on?" 

She said, "I can't tell you at this particular 



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time." And then when we were through with that part of 

the conversation, she said, "Why do you pay your taxes?" 

like it was some bad thing to do. 

Barbara Jeske, the highest ranking member of NXIVM, 

brags about the fact that she's off the radar with the 

IRS and has not paid taxes for years. 
Q Did Nancy Salzman ever tell you not to pay taxes to 

Washington state? 
A She didn't -- she never told me not to, but the way she 

questioned me believed -- made -- it caused me to believe 

that it was -- that why was I doing that -- 
Q Did she 

A -- why was I paying them. 

Q But you were the presence of NXIVM in Washington; 

correct? Your company and you were the presence here? 

A That's not -- that's not correct. NXIVM actually ran a 
business in Washington state. 

Q And in your declaration, you also have -- well, okay. 
What other conduct did you think was inconsistent with 
what NXIVM taught in terms of ethics? 

A I think that lying to people about people ' s character is 
a twisted form of ethics. Like, I was told several times 
that Barbara Bouchey was a full suppressive and that she 
was crazy. I was -- I was told by Nancy Salzman that her 
and Keith hypothesized that I was a full suppressive. 



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Q So you -- 

A I think that there ' s a lot of behavior that goes on 
within NXIVM that works to rip away at people's 
self-esteem and their self -understanding of themselves. 

Q Anything in written course material that encourages 
ripping people apart like that? 

A That's what I -- why I'm referring to that as twisted. 
They teach one thing but do another. 

Q I see. So people's -- people's conduct may not be 

consistent with the written teachings of NXIVM; is that 
correct ? 

A Well, the thing is, is that -- 
Q Is that correct? 

A -- if you're asking somebody to come in and pay $6,000 
for a course that is -- that the founder and the 
president of the company don't even follow, then to me, 
that's -- that's consumer fraud. 

Q All right. What other things did you observe that caused 
you to think that the behavior of the NXIVM officers 
deviated from what they actually taught? 

A I believe that NXIVM has collected cash that they don't 
claim . 

Q What's that based on? 

A Based on the fact that they have a cafe . They have an 
unlicensed cafe at their training facility. They sell 



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products within there. They collect cash. They used to 

have, like, little buckets all over the place. I believe 

that that cash is not reported. 
Q What's that -- what's your belief based on? 
A Based on the fact that I've been told by several people 

that they don't claim their cash. 
Q Who? Who told you that? 

A One is Barbara Bouchey. One is Nancy Salzman. 

Q Nancy Salzman actually told you they don't declare -- 

they don't pay taxes on the cash they collect from their 

little cafe? 

A Right. She also told me that they bring cash across the 

border from Mexico that they don't claim. 
Q Nancy Salzman told you that? 
A Yes . 

Q What other things does NXIVM do that's contrary to their 

written view of ethics? 
A I believe -- well, one thing is, is I believe that they 

manipulate people. 
Q What else? 

A Let's see. I believe that they sell a training program 
as a human development company, but a lot of their 
behaviors are very cult like, and it's my personal 
opinion that NXIVM is a cult. 

Q And what else? What else in terms of how their actual 



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conduct deviates from their written materials? 
A Let me think about this for a minute. 

And again, I apologize. I haven't reviewed their 

written material in a long time, so I don't know if I can 

move forward in regards to their written material . I can 

go forward with behaviors that I've seen. 
Q Have you fully answered your question -- my question that 

I posed to you? 

A At this particular time, because I haven't gone back and 
reviewed the course material, that's all I can recall at 
thi s moment . 

Q In your declaration, you say that NXIVM teaches that, 
quote, "anything is permissible that is necessary to 
advance the goals of NXIVM," unquote. Is that an 
accurate statement? 

A That ' s an accurate statement . 

Q Is there anything in writing where NXIVM says that 
"anything we do is permissible"? 

A It's not in their writing. It's in their behavior. The 
fact that I was lied to about Barbara Bouchey; the fact 
that I was lied to -- I believe I was lied to about the 
Plyams; the fact that I believe I was lied to about Toni 
Natalie; the fact that I believe that they spread rumors 
about me that were not true . 

Q How do you know that NXIVM lied to you about Barbara 



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Bouchey ? 

A Because Nancy told me she was a full suppressive and she 
was crazy. 

Q Is that the only basis you have for thinking that NXIVM 

has lied to you about Barbara Bouchey? 
A About a lot of people. 

Q No. I'm talking about Barbara Bouchey. 
A Okay. 

Q Let's focus on Barbara Bouchey. 
A Okay. 

Q Other than the fact that Nancy said to you, "I think that 
she's crazy, that she's a full suppressive," what else 
has NXIVM done to lead you to believe that you've been 
lied to about Barbara Bouchey? 

A Another incident is, is that there was a period of time 
where Keith Raniere had stopped talking to Barbara 
Bouchey, and what was happening was people were going 
around and saying "What do you think Barbara did that was 
so bad that even Keith won't talk to her?" 

And the thing is, is that I didn't know. And so 
finally I went to Barbara, and she said, "All I can tell 
you is I'm renegotiating my contract with him." 

That's all she could say until a much later date, 
and then she -- then when she disclosed that she'd been 
in a long-term relationship with him, she told me the 



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reason Keith stopped talking to her is because Barbara 
broke up with him. And so I believe that they were 
trying to do -- portray this bad thing that Barbara had 
done because they keep secrets of everybody that Keith is 
in a relationship with. 

Q And that's based upon what Barbara Bouchey told you? 

A Yes . 

Q Keith's old girlfriend? 

A (Witness nods head.) 

Q The one that they broke up? 

A Correct. She broke up with him. 

Q She broke up with him. 

So you're basing your understanding that NXIVM lied 

to you about Barbara Bouchey upon what Barbara Bouchey 

told you; correct? 
A Well, but the thing -- 
Q Correct? 
A -- that -- 
Q Yes or no? 
A But it also -- 

Q You can't answer yes or no, can you? 
A Well -- 

Q I'll ask the next question. 

A No. I'd like to finish answering that question. 
Q Can you answer that question yes or no? 



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A I would like to answer the question. 
Q Barbara Bouchey -- 

A You're asking me to answer a yes-or-no question that I 
believe, once again, doesn't -- a yes-or-no response -- 
we ' re not - - 

Q Fine. 

A You don't have me on the witness stand. We're in a 

deposition. Depositions have -- 
Q This is like a court -- this is like a court system. 
A I understand that, but depositions have a wider variety 

of things. So if you want me to answer the question, I'd 

love to answer it . 
Q I don't want you to answer that question. 
A Well, then I'm not going to answer any more questions 

until I get to answer it. 
Q Okay. Is it correct to say that NXIVM offered expensive 

advanced training courses? Is that an accurate 

statement ? 

A I'm not going to answer that until you let me finish 

answering the previous question. 
Q Okay. I think the previous question was: Is your only 

basis for concluding that you were lied to about Barbara 

Bouchey was what Barbara Bouchey told you? 
A No. It was based on a lot of things that I was told by a 

lot of people that I then found out were not necessarily 



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true, or I was told about people that I had personally 

knew was not true . 
Q All right. So back to the question. Is this an accurate 

statement that NXIVM's coursework is expensive advanced 

training courses? 
A I believe it is expensive. 
Q Do you have an advanced degree? 
A I do . 
Q In what? 
A In psychology. 
Q From what institution? 
A Antioch University. 
Q What year? 

A I think it was '89 through '92, if I'm -- you know, I 

think that ' s when I went . 
Q Have you ever used your degree? 
A Yes . 

Q In what way? 

A In private counseling. 

Q And where did you obtain your undergraduate degree? 

A A couple of different places. I was in the United States 
Navy for ten years, and during that time, I obtained my 
associate degree from there. And then after that, I got 
my undergraduate the last two years at Evergreen State 
College in Olympia, Washington. 



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Q So what are your other -- what are your undergraduate 
degrees in? 

A It was in holistic studies and psychology. 

MR. CROCKETT: How are you doing? 
THE REPORTER: Fine. 
Q (By Mr. Crockett) Is this an accurate statement, that 
when anybody was -- left NXIVM speaks out against the 
organization or its leaders, NXIVM immediately initiates 
complex lawsuits that are intended to bankrupt the 
nonbeliever suppressive and destroy their reputations? 
A That is what I believe. 

Q How many students or members do you think NXIVM has had 

since its inception? 
A I would assume -- when I left, it was a little over 

6,000, so I would assume that by now it's probably over 

7,000. 

Q And of those 7,000 members, how many of them would you 

say NXIVM has initiated lawsuits against to destroy their 
reputations ? 

A Let's see. There's Barbara Bouchey. There's me. 
There's Kim Woolhouse. There is Toni Natalie, Joe 
O'Hara, the Plyams, Yuri and Natasha Plyam. And from my 
understanding, that they are working on doing that if 
Becca Friedman doesn't come forward with what they want 
from her, that they're going to initiate a lawsuit 



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against her. 

Q So I've heard seven lawsuits of the 7,000 members. 

A Well, I think the thing with that is, is that most people 

are afraid to speak out because of NXIVM's lawsuits. 
Q Are there -- are you aware of any other lawsuits other 

than the seven? 
A I'm not aware of any. 
Q Now -- 

A But I'm also not aware of anybody who has been vocal and 

blown the whistle. 
Q Do you -- 
A -- besides the seven. 

Q -- consider yourself a whistleblower ? 
A I do . 

Q And what do you need to blow your whistle about? 

A Well, I think I was very clear in my declaration about 
that. I was told certain things about Keith that I at 
the time believed were true. Then when I found out other 
things about him, those are things that then eventually 
caused me to leave . 

The one thing is the -- what I believe is compulsive 
gambling in the commodities market and losing over 
seventy thousand -- or seventy million dollars of their 
members ' money in the commodities market and using 
several people, NXIVM members, to open accounts for him 



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to gamble in. I believe that that's a problem. 

Then I also believe that there's a problem with the 
sexual behavior. Those two things then caused me to have 
great concern because I had misrepresented him in 
relationship to a lot of people that I had -- trusted me, 
in that I told them about Keith Raniere ' s character. So 
I believe that what I did was the reasonable, ethical, 
moral thing to do, was to let people know that I had 
misrepresented him, and in doing so, I blew that whistle 
on his behavior. 

Q And that's the basis for your whistleblowing belief? 

A Yes . 

Q So your whistleblowing belief is based upon what you told 
me were two aspects of Keith's personal life, his 
compulsive gambling and his sexual behavior; correct? 

A Correct . 

Q Why do you think you have the right to go to the press 
and expose anybody's personal life about their sexual 
behavior ? 

A Well, mostly, I didn't do it with the press. I think 

I've talked to the press a couple of times. 
Q About Keith's sexual behavior? 

A Correct. But that was already well-known. That was 

already well-known before I ever talked to the press. 
Q What gives you the right to go to the press or any third 



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party to talk about anybody's sexual behavior? 
A Well, it's not about anybody's sexual behavior. I think 
the thing with that is, is that Keith represents himself 
as one thing. And the thing is, is that had he fully 
disclosed that those are activities that he participated 
in, I would have never bought a program. I would have 
never opened a center for them, any of those kinds of 
things . 

Q Let's talk about the first of two items that you blew the 
whistle on, his compulsive gambling. How do you know 
that Keith Raniere is a compulsive gambler? 

A Because I believe that he's lost over $70 million in the 
commodities market. 

Q Who told you that? 

A Barbara Bouchey and Yuri Plyam. 

Q Okay. So his former girlfriend and his commodities 

broker ? 
A Correct . 

Q All right. What did -- what did Keith Raniere tell you 
about those losses? 

A Well, also, Toni Natalie told me that before Keith -- 
before those cases that he had actually opened 
commodities markets in Pam Caf ritz ' s name and in Karen 
Unterreiner ' s name and had lost that money, and that 
Keith also would go to casinos -- 



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Q All right. 

A -- and that he -- while she was his boyfriend [sic] in 
CBI, that he also participated in several gambling 
ventures . 

Q So you're basing your understanding of Keith's compulsive 
gambling on a former girlfriend; is that correct? 

A There were actually several people. It wasn't just one 
person . 

Q But you just mentioned Pam Caf ritz . 
A Correct . 

Q All right. So with respect to the commodities story, are 
you telling me that a licensed commodity broker revealed 
to you the confidential aspects of an investment in 
commodities ? 

A He didn't -- he didn't say the actual investment. He 
just told me who Keith had gambled in the commodities 
market with. So he didn't actually go through the actual 
numbers of that. The only thing that I know is what has 
been in -- what Barbara Bouchey had told me. And 
originally, she had told me that Keith had lost $1.7 
million of her money and that he -- they had gone and 
borrowed money from her cousin -- I don't remember her 
name. Chrissy is the only thing I remember -- and then 
also Noel Neilson and then also Michael Sutton and that 
that total amount was approximately about $5 million. 



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Then she also told me that he had lost -- 
Q She being who? 
A Barbara Bouchey . 

Q So you're getting all of this information from a former 

girlfriend? 
A I believed it was true. 

Q All right. And then Keith's sexual behavior, don't tell 
me, but -- I guess I'm -- let me withdraw the question. 

Is it correct to say that your understanding of the 
repulsive aspects of Keith's sexual behavior comes from a 
former girlfriend? 

A Actually, it comes from more than a former girlfriend. 

Q Well -- 

A It actually comes from Barbara Bouchey. 
Q A former girlfriend. 

A And then it also comes from two other women that were in 
that meeting. One was Kathy Ethier, who Keith had made 
advances on, and then also Angela Ucci, who Keith had 
made advances on. 

Q All right. 

A And then also Toni Natalie. 
Q Former girlfriend? 
A Correct . 

Q All right. So you've named four women that Keith's had 
relationships with or that he's attempted to have 



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relationships with as the basis for your exploding to the 
press Keith's sexual history; is that correct? 
A Well, the thing is that while I was in NXIVM, Keith was 
never open about who he was dating, but -- oh, actually, 
I'll -- but there were several women that I had 
suspected . 

And also, another person was Esther Chiappone, who 
told me personally that she had a sexual relationship 
with Keith . 

Q So is there something wrong with members of NXIVM having 

sexual relations with people? 
A I think when it's done under the guides of manipulation, 

it is -- that is wrong in my -- in my moral code. 
Q Did you think other people in NXIVM had -- were having 

sexual relations with each other? 
A I don't know that. I think that a lot of that stuff was 

kept secret . 
Q So the -- 

A But my issue is with the founder of the company having 
what I believed was setups in regards to manipulating 
women into having relationships. Like, he had told 
Barbara Bouchey that they -- that he was her boyfriend 
without telling Barbara Bouchey that he was having 
multiple sexual relationships. Same thing with Toni . He 
told Toni that he was her boyfriend without sharing with 



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Toni that he was having multiple sexual relationships. 

In my book, in my moral fiber, that's deviant -- 
Q And you got that -- 
A -- and lying and manipulation. 

Q You got that information -- you got that information all 

from Keith's old girlfriends; correct? 
A They were the only ones that would speak up. 
Q Right. And so -- but you were willing to speak to the 

press about it; correct? 
A But that information -- 
Q Yes? 

A -- was already out there. 

Q But you were willing to speak to the press about it; 

correct ? 
A Right. 

MR. CROCKETT: All right. We need to 
change the tape, so... 

THE WITNESS: It might be a good time 
to go to the bathroom. 

MR. CROCKETT: Do you want to -- would 
you like to get lunch? 

THE WITNESS: I brought lunch. I 
don't really need much time. 

MR. CROCKETT: Okay. Why don't we go 
off the record right now. 



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THE VIDEOGRAPHER : Okay. As we go off 
the record with permission of counsel, the time is 12:13, 
and this is the end of Disk No. 1. 

(Recess 12:13 - 12:47 p.m.) 

THE VIDEOGRAPHER: We are now back on 
the video recorded record. This is the beginning of Disk 
No. 2. The time is 12:46 p.m. Please proceed. 

MR. CROCKETT: The next document I'll 
ask to be marked as Dones Exhibit 7. 

(Exhibit No. 7 marked for 
identification. ) 

EXAMINATION (Continuing) 

BY MR. CROCKETT : 
Q Do you remember receiving Dones Exhibit 7, which is a 

letter dated March 22nd, 2010, to yourself? 
A No, I don't remember getting this. 
Q Do you recognize that address? 
A Yes. That is my old address. 

Q Did you receive demand from NXIVM's lawyers to return 

their course and instructional materials? 
A I received the demand, and I -- from May 15th until March 

of two thousand and -- May 15th, 2009, to March of 2010 



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attempted several times to get NXIVM's materials back to 
them and got no response from actual -- their -- well, I 
got responses, but at the last minute, they just stopped 
dealing with me. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) Did you ever receive any demands from 
NXIVM lawyers to return their course materials? 

A I think I've answered that. I said yes, I did, and that 
I have -- I had worked from several -- for several months 
to try to get their materials back to them. I included 
that in my declaration, all the e-mails back and forth 
between the attorney that I had hired in New York, and 
when I could no longer afford an attorney, all the 
e-mails that went back between -- I don't remember his 
name -- Andrew something or -- I can't remember his name, 
but mostly I worked with Pamela Nichols . 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) Did you ever receive any demands from 

NXIVM to return their course materials? 
A I think I'm answering your question. 

Q Well, just answer yes or no, and then I'll ask you -- 

A But I think it requires more than that. 

Q Well, then I'll go on and ask you what you did. 



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A Okay. 

Q Did you ever receive any demands from -- 
A I did. 

Q Let me finish the question. 
A Okay. 

Q You don't want to go a second day for your deposition, do 
you ? 

Did you ever receive any demands from NXIVM's 
lawyers to return their course materials? 
A I did. 

Q What is the first date you recall getting such demand? 

A I don ' t remember the date . 

Q Was it sometime in 2010 or 2009? 

A 2009. 

Q So in response to that -- let's kind of step through 

that . 
A Okay. 

Q -- did you immediately box up your materials and send it 

to the demanding lawyer? 
A I did not . 

Q In response to that, did you call the demanding lawyer 

and say, "They're here. You come and get them"? 
A I didn ' t call. 

Q Is there any reason why you just didn't box up the 
materials and return them? 



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A At the time, I didn't know what my financial future was 
to be, and so I asked NXIVM through several e-mails, 
which I have provided as evidence in my response to 
NXIVM' s complaint -- it was agreed upon by Pam Nichols 
that she would arrange for payment. I gave her dates 
that I was available to be available for FedEx, UPS, 
whoever was going to come pick them up, and never got a 
response back from Pam Nichols in regards to that. 

Q You wanted payment for what? 

A I didn't want payment. I just wanted NXIVM to pay for 
the shipping. They were their materials, and I wanted 
them to send them back. 

Q Did you ever return those materials? 

A No . 

Q Where are they today? 
A They're in my attic. 

Q Is there any reason why you didn't bring them today? 
A I wasn't asked to. 

Q The -- have you ever used the practice of disseminating 

your thoughts or opinions about NXIVM through a web-based 
document service like Google Docs or Windows Live? 

A No . 

Q In other words, where you -- to try and avoid having to 
ever produce documents to claim -- and to be able to 
claim you don't have possession of them, have you ever 



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done things like uploaded documents to internet services 

like Google Docs? 
A I have uploaded them to Google Docs but not made those 

available to anybody other than Barbara Bouchey. 
Q And did you produce any of those documents today? 
A No. They're all just court documents. 

Q And is there any reason why you haven't produced any of 

those documents today? 
A You asked me to produce documents from July 9th, 2010. I 

believe that I have done that as -- to the best of my 

understanding. 

Q So the documents that you've uploaded to Google Docs 

are -- predate that date? 
A Correct . 

Q What kind of documents do you have uploaded there other 

than court documents? 
A That's it. 
Q How did -- 

A I don't -- I don't believe that that even exists anymore, 
so . . . 

Q And when you -- did you circulate a draft of your 

declaration by uploading them -- it to -- 
A No . 

Q -- Google Docs? 
A No . 



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Q I'm going to place in front of you -- I'm not going to 

mark it, but it's your declaration. 
A Mm-hm. 

Q And I'm going to ask you about Exhibit I. 
A H, I. Yes. 

Q Is Exhibit I a document that you authorized before it was 
sent ? 

A I authorized all of it, except I didn't authorize that -- 
I believed when we sent this out that it was going to be 
that if we didn't get a response from NXIVM that we would 
go to the press about our resignation. I did not 
understand that it said that if we didn't get a payment. 

Q What did you think you were going to go to the press 
about when you -- 

A Our resignation. 

Q -- sent this letter? 

So when it says "If these requests are not met, we 
will move forward by contacting the press," you said 
what ? 

A About our resignation. 

Q The second page contains a demand for $250,000 from 
yourself -- or for yourself, apparently. Do you see 
that? 

A Yes . 

Q Is that a demand you were making for money? 



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A I did ask for that in regards to all of the value that I 
had created in the Tacoma center, but that also included 
chairs, TVs, DVDs, all of that kind of stuff. And I also 
understand that Keith Raniere is a tough negotiator based 
on my conversations with Barbara Jeske and Nancy Salzman, 
so I asked for more hoping that he would consider giving 
me some value for what I had created. 

Q So if I understand your testimony, you were asking for 
money for which you knew you were not entitled, and if 
you didn't get it, you were going to the press? 

A I didn't understand that that's the way the letter was 
written . 

Q Did you see a different version of this letter that said 
something other than your demand for money and -- 

A I never saw the version of the letter. We talked about 
it. Barbara Bouchey worked on this on her computer. We 
talked about it several -- for several different hours 
while I was working on other things, and so I never saw a 
final version of it before it went out. 

Q Do you have a listing of everything adding up to 
$250,000, or was that just a false number? 

A That was just I believe that Keith is a rough negotiator. 

Q So you're willing to lie? Is that what you're saying? 

A I don't understand your comment. 

Q When it comes to asking for money, you're willing to lie 



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about what you're entitled to to inflate matters? 
A No. I think that that's good business sense, is you 

always ask for more than you belive the person will come 

back with. I mean, people do that with their properties. 

People do that with all different things. 
Q Did you -- when you asked for this $250,000, did you have 

a list adding up to $250,000 as to what you were owed? 
A I didn't have any list. This was a very stressful time 

for all of us . 
Q So when you demanded the $250,000, you were -- 
A It wasn't a demand. 
Q -- you were lying, weren't you? 
A It was a request. 

Q And it was a lie because you weren't entitled to the 
money . 

A Well, based on their teachings, they teach about value 

exchange and giving somebody the value of what they have 
earned, and if you don't have an equal value exchange, 
then you lower somebody's self-esteem. 

Q So you -- 

A So based on what I was taught in NXIVM, I believed that I 
had the right to ask for -- I knew I was no longer going 
to participate in the center that was created out here. 
I believed that there was a value to the center in that 
they would move it to a different location. Knowing that 



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they were going to move it to a different location, my 
assumption was, is they were going to need all of those 
items: chairs, TVs, DVD players, file cabinets. I had 
lots of money in copy costs for student files, coach 
notes, all of those different things. 

Q And did you have a valuation done of that to justify your 
demand for $250 , 000 ? 

A I was in New York when I found out the information about 
Keith's gambling and sex problems. 

MR. CROCKETT: Move to strike as 

nonresponsive. 
Q (By Mr. Crockett) Did you have any itemization 

justifying your demand for $250,000? 
A I did not . 

Q Now, in your declaration you say that "Whenever he was 

asked how NXIVM's payment plan differed from typical MLM 
schemes, Raniere would always evade answering the 
guest ion . " 

A That ' s correct . 

Q Is that an accurate statement? 
A (Witness nods head.) 

Q Did you -- what's the basis for that statement? 

A He was asked that several times in forums. Keith had 
always talked about the fact that he believed that MLMs 
were unethical . When I came into NXIVM, I was involved 



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in an MLM, the same one that a number of people were 
involved in at my same training. And during that time, 
between him, Barbara Jeske, and Nancy Salzman, they 
talked about how unethical MLMs were several times. 

And so when -- several times, looking at the pay 
structure of NXIVM, I could not see how that was really 
any different. Really, the only different [sic] was that 
none of us had contracts to protect our investments that 
we put into it, where with a traditional MLM company 
there are contracts . 

MR. CROCKETT: Move to strike as 

nonresponsive. 
A It's -- I'm answering your question. 

Q (By Mr. Crockett) Let's focus on the basis for your 

statement that Raniere would always evade answering the 
question . 

A Okay. 

Q Did you see him evade answering the question? 
A Yes . 

Q All right. What would he -- what would his response be? 
A He wouldn't respond to that. 

Q So not responding meant that he was evading a question? 
A Right. 

Q And what was the question? 

A "How is this any different than MLM?" 



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Q And he just would not respond? 
A Or he would evade the question. 
Q How so? 

A By not answering it. By saying, "You know, well, you 
know, I'm not going to go into that at this particular 
point," those kinds of things. He never answered that 
question . 

MR. CROCKETT: The next document I'll 
ask to have marked is Dones Exhibit 8. 

(Exhibit No. 8 marked for 
identification. ) 

Q (By Mr. Crockett) Dones Exhibit 8 appears to be a 
schedule from your bankruptcy filings. Does this 
document look familiar to you? 

A I guess so. My attorney sat down and went through this 
with me . 

Q Did you really list as an asset worth zero dollars the 

NXIVM student list? 
A I don't remember putting that on there, that I put on 

NXIVM student list. That's the only list that -- I mean, 

the list had no value to me. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) Do you remember when putting together 



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your bankruptcy schedules deciding that you were going to 
list as an asset with zero dollars NXIVM student list? 
A I don't remember putting that on there. 

Q Do you deny that that statement is on your schedules? 
A No. It's right here, but I don't remember putting that 

on there or why I would put that on there . 
Q What does that student list look like today? 
A I have no idea . 
Q Where is it? 

A Well, what I did was I put together an e-mail list of the 
students that came through the Tacoma center, the active 
ones, so that we could send them e-mails about, you know, 
was the school closed because of snow, those different 
kinds of things . 

And so that's the only list that I ever have. I 
produced that myself with the help of the other proctors, 
and I was never provided a list by NXIVM. 

Q Do you believe that that student list is NXIVM 
proprietary? 

A It's their list. 

Q Then where is it today? 

A I don't -- my list? 

Q The one that you have on Dones 8, where is that list 
today? 

A I have no idea. My assumption is it's with NXIVM' s 



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property up in my attic. 
Q What else do you maintain of NXIVM's property up in your 
attic? 

A I have coach notes -- well, I have -- what I did was -- I 
had a lot of notes, and because I was moving to a much 
smaller facility, I took all of the extra coach notes and 
all of the other student notes that I had, I made one 
file of master copies of each of those notes, sets of 
notes, the coach notes and the student notes. I took all 
of the extra copies and burned them so that they would be 
protected. I didn't shred them. I didn't recycle them, 
any of those kinds of things. 

So I have coach notes, student notes, DVDs, student 
files, display sashes, PalmPilots, flip -- some flip 
charts, you know, that we put -- we would write stuff on 
for the classes. So I have some flip charts we never got 
to recycle . 

What else do I have of theirs? I have certain 
things that we laminated, you know, in regards to, like, 
the mission statements. We took the mission statements 
and laminated those so they would be available to use 
when students came in who didn't bring their binders with 
them . 
Q Anything else? 

A I am trying to think. I don't remember if I have copies 



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of the stuff like mission statements or any of that kind 
of stuff. 

Q Do you realize today that NXIVM wants all of that back? 

A I understand, and I want them to have it back. I tried 
for months to get it back for them. 

Q And tell me when you burned some of that material . 

A Well, their actual materials that belonged -- that were 
part of the center, I burned those materials -- I don't 
remember the exact time I burned those. It was before I 
moved, so sometime late -- sometime probably in the fall 
of last year. 

And then after I returned home from NXIVM and 
realized I wasn't going to work for them any longer, I 
took all of my student notes that I had as a student and 
actually burned all of that material. 

Q Was that recently, after this lawsuit started? 

A No. All of this -- the stuff that I burned of my own 
personal stuff, I did that before -- right after I left 
NXIVM, so that would have been in May or June of 2009. 
The other stuff I burned actually, I think, before I 
filed bankruptcy. 

Q What — 

A But I did maintain a master copy of theirs . 
Q Why did you burn the material? 

A Because I didn't have space to store it all in. It was 



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just copies of notes. 
Q Why didn't you just throw it out in the trash? 
A Because it's -- I didn't believe that that was a safe 

thing to do with their materials . 
Q Because it was proprietary and confidential materials; 

correct ? 
A Right. 

Q Why did you file bankruptcy? 

A Because I took out a lot of business debt to build 

NXIVM's center, and when I left NXIVM, I didn't believe 
that I was going to have the capacity, based on the 
skills that I had left, to be able to pay that debt off. 
And so I was in over my head, and so I made a decision to 
file bankruptcy. 

Q Did you file bankruptcy because NXIVM was threatening you 
in any way? 

A No. I don't believe NXIVM was threatening me. I believe 
that they were asking for their materials. I tried 
several times to negotiate for them to send them back. 
The attorneys in New York agreed to that, and then I 
stopped hearing from them. 

Q Now, do you believe that Scientology uses tactics of 
litigation to silence its whistleblowers ? 

A From the research I've done on the internet, I believe 
that that ' s true . 



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Q That's the only basis you have for that, what you read on 
the internet? 

A Correct. I've read several, several documents about 
Scientology . 

Q Do you believe that NXIVM uses the confidentiality as a 
weapon regardless of what the whistleblower ' s claim may 
be? 

A I do — 

Q How -- 

A -- based -- 

Q How does NXIVM use the confidentiality agreement as a 
weapon ? 

A Because I believe that I have not disseminated their 

information, their materials. And what I have mentioned 
is my personal experience, and I believe that that's my 
first amendment right. And because I've shared my 
personal experience, they've come into my bankruptcy 
court and made several claims against me that I believe 
are false . 

Q You realize that NXIVM' s contention is that you are using 
NXIVM material with the press, i.e., the videotape; 
correct ? 

A I don't believe that that's their material, so that's 
where we differ. And besides that, NXIVM was in my 
bankruptcy court before that. 



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Q Because you hadn't turned over material in your attic- 
correct ? 

A The thing is, is I don't know why they came into my 

bankruptcy court. I don't know what their motivation is. 
I'm not them. But the thing is, is that I think I've 
made several attempts to try to get their materials back. 

I even offered -- they moved one of the centers to 
Vancouver. They moved -- they split the center, the 
Tacoma center. They moved one to Vancouver, BC; they 
moved one to Seattle. And I suggested that Wendy 
Rosen-Brooks, who was the highest ranking student -- she 
was an equal rank of mine. I suggested that either her 
or Charmel Bowden, who was the next highest ranking 
student on the West Coast, that I turn over NXIVM's 
materials to them so that they could use them at the 
Seattle center. So I think I've gone way out of my way 
to give their materials back to them. 

Q Other than just dropping them off to somebody at NXIVM; 
right ? 

I mean, you could just do that. This lawsuit would 
have never happened if you had just dropped your 
materials off to somebody, but you're still holding onto 
them; right? 

A Well, great. I'll drop them off here tomorrow. 

Q Let me read this statement to you from your declaration. 



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"Moreover, it is also my understanding based upon 
information and belief that NXIVM's various lawsuits are 
primarily based on accusations rather than evidence and 
that its goal is to force its enemies to concede unless 
they can find pro bono help or attempt to defend 
themselves pro se . " Is that an accurate statement? 

A I believe that's true. 

Q What's that based on? 

A My own personal experience. They -- when NXIVM came into 
my bankruptcy, they made a complaint that I refused to 
return their materials. I don't believe that's true 
based on 20-some pages of e-mails that went back and 
forth between myself and the firm that Pamela Nichols 
works at. I believe that I've gone way out of my way to 
try to return their materials. 

Q Why didn't you -- when you got that lawsuit or the notice 
of that lawsuit, why didn't you just go down to Federal 
Express, put the materials in a box, and send it to 
NXIVM? 

A Because I don't have the money to do that. 

Q Did you hire Mr. -- your first lawyer's name, what was 

his name? 
A Mr. Tiffany. 

Q Tiffany. How did you find Mr. Tiffany as a lawyer? 
A Through Pre-Paid Legal . 



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Q You have a Pre-Paid Legal defense program you're in? 
A I have a Pre-Paid Legal membership, yes. 

Q And have you spent any money on the adversary proceedings 
other than your Pre-Paid Legal expenses? 

A My understanding, talking to Mr. Tiffany, is, is that 

once the adversary proceeding took place, is that we were 
beyond our fee agreement and that I could not afford an 
attorney. And so based on his dealings with the actual 
TRO thing, he said that he was going to step down because 
we were beyond our fee agreement and I couldn't afford to 
pay him, and I have been yet able to retain pro bono 
help . 

So the only money that I've spent is on parking, 

paper, printing, those kinds of things. 
Q Don't you think you would have saved all of that by just 

going down to Federal Express and putting your documents 

in a box and sending it? 
A I don't know that. I don't know if I would have sent the 

materials back if NXIVM still wouldn't have come into my 

bankruptcy . 

Q So because NXIVM sued you, you're taking the -- you 
believe that you don't have any obligation to return 
their materials? 

A No. I want to return their materials. 

Q All right. 



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A I have wanted to ever since I left. 

Q How much money do you need to return their materials? 

A I have no idea what it would cost. I mean, it's not like 

it's a binder. It's not like it's a couple of binders. 

I had two filing cabinets full of stuff. Now, part of 

that doesn't exist anymore because I burnt it, but I 

don't have any idea what it would take to ship it back. 
Q And you've made no attempt to determine that; correct? 
A Correct. Well, the thing is, is Pamela Nichols agreed to 

arrange for payment. I assumed she was being honest. 
Q So I'll have a messenger there at your place tomorrow to 

pick up all of those materials. Would that be 

acceptable ? 

A That's acceptable. Is NXIVM going to drop their suit 

against me? 
Q No. 

A Then -- see, then it wasn't just about returning their 
materials . 

Q All right. So you're not willing to turn over the 
materials now without dropping the suit; correct? 

A I didn't say that, but you pointed out that if I 

returned -- had just returned them, NXIVM would have -- 
wouldn't have come into my bankruptcy. So it presupposes 
that if I return the materials that NXIVM would then drop 
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it's just based on that. 
Q Well, because since then you've gone to the press with 

other materials . 
A Which is -- no. I've gone to the press with my personal 

experience -- 
Q Yes . 

A -- none of NXIVM's materials. 

Q Now, your declaration says: "Many of these women were 

told that they were the chosen one." Is that an accurate 
statement ? 

A That's what I believe. 

Q Where did you get that information from? 

A I got it from Barbara Bouchey and Toni Natalie. 

Q Two former girlfriends; correct? 

A Correct . 

Q You say, "I was informed and believed that NXIVM had lied 
to me about many of Raniere ' s /Vanguard ' s supernatural 
abilities . " 

How did you figure out that you had been lied to 
about Keith Raniere ' s supernatural abilities? 
A Because we can ' t find any proof of any of that anywhere . 
Q Proof of what? 

A Him breaking the hundred yard dash -- he doesn't 

physically have the body type to do that -- him winning 
the East Coast Judo championship when he was 12; his 



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ability to teach himself high school math in a day and a 
half when he was -- I don't know. I don't remember the 
age. I don't have that document right in front of me, 
but it was something like 12 -- that he has a 240 IQ; 
that he's the third top problem solver in the world. 
What does that even mean, you know? 
Q So because you can't find proof of that, you think he's 
lied to you? 

A Yes. Well, and just based on other information that's 
out there now. When I first started taking NXIVM in 
2000, Google wasn't what it is today. Google has all 
kinds of -- I mean, if you Google Keith Raniere, there's 
a lot of negative information out there. That 
information was not available to me when I first started 
taking courses. Had that been out there, I wouldn't sign 
up today to take a course . 

Q Do you know that NXIVM has a policy of not defending 

itself in the press or attacking its attackers publicly 
in the press? 

A No, I don't know that. 

Q Have you ever heard -- have you ever seen any publication 
from NXIVM or Keith Raniere or Nancy Salzman attacking 
you personally? 

A No, but I have heard. 

MR. CROCKETT: Move to strike as 



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nonresponsive. 

Q (By Mr. Crockett) Let's focus on things like you do. 

You go to the press. You talk about people's sex lives. 

You talk about their gambling addictions. You talk to 

multiple members of the press. 
A I don't do that on a general basis. 
Q But you do that on a specific basis. 
A Right, because Keith Raniere is a figurehead -- 
Q Yeah. So let's -- 
A -- and he runs a company -- 
Q Yeah. 

A -- that deals with people on an emotional level, and I 

believe that those things need to be known. 
Q I can tell you I would find it deeply offensive if 

somebody talked about my sex life in public. 

And so when you went and spoke to the press about 

Keith's sex life in public, you were attempting to hurt 

him; correct? 

A No, that's not true. I was attempting to inform people. 

And the thing is, is that was already out there. I never 

actually -- it was out there, that he did. 
Q So you felt justified in talking to the press about 

Keith's sex life because others were doing it? 
A I believe that I was informing the public, which is my 

first amendment right to do. 



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Q Do you believe that you had -- do you believe you had the 
right to talk about Keith Raniere ' s sex life to various 
reporters because his disgruntled girlfriends were doing 
the same thing? 

A I believe that I had a right to tell people that because 
I had sold hundreds -- probably hundreds of people on 
Keith's character. And so I believe that I had a right 
to warn the public because I would want to know that if I 
was going to enroll in a program where somebody was 
selling him as a Buddhist monk kind of figure. 

Q Do you think Buddhist monks are celibate? 

A I don't have any idea. 

Q Obviously not. 

Do you -- let me ask you this: Have you ever seen 
NXIVM or Salzman or Raniere ever publish anything on the 
internet or in the press critical of you? 

A I have -- I have not seen them publish anything, but what 
I do know is, is that they talked a lot before -- even 
before I left and after I left. 

Q How do you know that? 

A I had friends who went -- well, I had friends who went to 
a meeting in Seattle that Nancy Salzman came out to do 
after I left, and I heard that Nancy had said some very 
negative things about me. 

Q Who told you that? 



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A Several of my friends who were there . 
Q Name one . 

A Barb Bell, Kevin Hlas, Andrew Dallow, Kristi Lahusen, 
Jeff Johnson . 

Q These are people who have -- who heard Nancy Salzman 

saying negative things about you? 
A Correct. And as far as I understand, that was 

actually -- that meeting was actually recorded. The same 

one up in Seattle or up in Vancouver, BC, was recorded. 

Those will be things that I'll be requesting in my 

discovery . 

Q What negative things were said about you that you were 
told? 

A I don't recall that right off the top of my head, but I 

can gather that information. 
Q So let's focus on, again, my question. Do you know if 

NXIVM has ever done what you've done to Keith Raniere, 

that is, go to the press and talk about you, your 

personal life? 
A I don't know that they've ever gone to the press in 

regards to that, but they did that within their 

organization. Nancy Salzman told people that I was a 

full suppressive. 
Q You consider that an insult? 
A I do . 



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Q That's all you can remember she said about you? 

A Well, she also said that Barbara Bouchey was crazy. I 

mean things like that. 
Q But no, I'm talking about you. 
A She also told me about -- 
Q I'm talking about you. 

A Well, this is what happens within the organization. 

Q Well, but let's focus on how you feel that you were 

insulted by NXIVM. The only thing I've heard, only one 
thing, is that -- is that somebody has said you're a full 
suppressive . 

A She's also said I'm a compulsive liar. She's also said 

that I'm not emotionally honest. She's also said -- what 
else has she said? -- that I'm defiant. She's also said 
a lot of different things about me. 

Q And that's it? These are -- you've summarized 
everything ? 

A As far as I know. 

Q Has any of that ever gotten outside of the NXIVM 
organization into the press or -- 

A Not that I'm aware of. 

Q -- the blogs? No. 

Your declaration says: "NXIVM has been involved for 
more than seven years in a civil lawsuit against Rick 
Ross, a noted cult investigator and deprogrammer . " Do 



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you see that -- or do you remember saying that? 
A Yes . 

Q Where did you get that information? 

A It's all over the internet. All you have to do is go 
into Google . 

The other thing, too, is I know that they've been 
involved -- based on conversations that I've had with 
Nancy that they've been involved in a lawsuit. 

Q When did you -- when did -- 

A It was also -- 

Q -- Barbara Bouchey first tell you that she was 
dissatisfied with NXIVM or Keith Raniere? 

A I think it was probably about six months before we left, 
if I am recalling correctly, that she was dissatisfied. 
We went through a series of arbitration meetings where 
Keith had assigned Barbara to be the arbitrator, and 
Nancy Salzman did arbitration with the entire Pacific 
Northwest proctor group. 

Q Give me the earliest date that you recall that -- 

A I don't have a date in my head. 

Q Well, I mean, estimate it. Was it sometime in 2010? in 
2009? 

A Well, it couldn't have been in 2010. I was already gone. 

So late 2008, maybe early 2009. 
Q And what were the first things Barbara Bouchey was 



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telling you about her dissatisfaction with NXIVM? 
A I think -- well, she didn't disclose the whole sexual 

relationship with Keith until April of 2009, but a part 

of what we talked about was Nancy's behavior, that Nancy 

was what we both considered and had experienced -- or at 

least I can speak for myself, is very abusive behavior 

from Nancy Salzman. 
Q Did Barbara Bouchey tell you in 2008 that she wasn't 

happy that Keith Raniere was having sex with multiple 

women without telling her? 
A She didn't tell me that until April of 2009. 
Q Did any other woman tell you that they were unhappy that 

Keith Raniere was having sex with other women while 

having sex with them? 
A Not until after I left and I met Toni Natalie -- 
Q So -- 

A -- and she told me the same thing. 
Q She told you that? 
A Correct . 

Q Any other woman tell you that? 

A Kathy Ethier told me that she was upset by Keith's 

behavior towards her, and Angela Ucci shared with me how 
she believed that she was set up by Pam Cafritz in 
regards to Keith. 

Q Who is Karen Woolhouse? 



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A Who? 

Q Karen Woolhouse. 

A Karen? I don't know a Karen Woolhouse. 
Q What's her first name? 
A Kim . 

Q Kim. Who is Kim Woolhouse? 

A Kim was my business partner, and she's also my domestic 
partner . 

Q And when you say "business partner," you mean business 

partner in NXIVM? 
A In Global Solutions . 

Q And Global Solutions . So Global Solutions -- 
A Not NXIVM. In, I-N, in Global Solutions. 
Q In Global Solutions? 
A Correct . 

Q So Global Solutions was in business prior to you having 

anything to do with NXIVM? 
A Correct . 

Q What was Global Solutions ' s business? 

A We did -- we were both medical massage therapists. We 
were also in a network marketing company called 
Mannatech, and then I also did some counseling. 

Q Did she do counseling? 

A No . 

Q Does she have a degree? 



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A No . 

Q All right. So when you became affiliated with NXIVM, 

what was her position in NXIVM? 
A Kim was a proctor, and she, for a period of time, was a 

salesperson but lost that salesperson status . And Kim 

also taught Ethos classes. 
Q Did the two of you come into NXIVM at approximately the 

same time? 

A Yes. We took the same class together. 

Q Now, when you quit NXIVM, did you -- how did you quit? 

Did you resign? Did you -- was it at the video meeting? 

I mean, what was the formal thing which said, "I'm done. 

I ' m out of here . " 
A We had made a decision -- pretty much, I had made a 

decision after the second day meeting that I could no 

longer belong to NXIVM. I think that -- well, I can't 

speak for anybody else. That's when I made my decision. 
Q Well, I'll ask you about Ms. Woolhouse. But -- so, I 

mean, did you say "I'm out of here" or did you send a 

letter of resignation or did you just stop attending or 

stop doing anything? What happened? 
A Well, I think you know that. You've already showed me 

the resignation letter. 
Q The letter. All right. That's what you consider to be 

the "I'm done" letter? 



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A Correct . 

Q All right. Now, tell me about Ms. Woolhouse. Did she do 
anything formal, or did she just sort of drift away? 

A I think her name is on that letter also. 

Q And what does Ms . Woolhouse do for a living today? 

A She still practices as a massage therapist. She works 
for Pierce College. She works in their international 
student position. And she's also -- well, she doesn't do 
it for a living yet, but she's also taking classes with 
H&R Block. 

Q All right. You said she works for Pierce College? 

A Pierce College. She works in their international student 

division as a part-time temp employee. 
Q And she has the same address as you have? 
A Correct . 

Q And she filed bankruptcy the same time you did? 
A Correct, because we had -- in our business, we had mutual 
business debt. 

Q What was that -- what was that mutual business debt? 
A I've already answered that. 

Q Well -- have you ever seen Keith Raniere give lectures on 

the topic of not paying taxes? 
A I think that I've been in forums where he has talked 

about paying taxes . 
Q Well, I think my question is: Have you ever been in an 



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intensive or some sort of instructional period where 
Keith Raniere is saying things like, "I don't believe in 
paying any taxes to any government"? 

A I don't recall that he's actually come out and said those 
exact words, but he has said things that led me to 
believe that he doesn't agree with paying taxes. 

Q Well, I don't agree with paying taxes. Does that make 
me -- is that the same thing as saying "Don't pay any 
taxes to any government"? 

A Well, I think there's a difference between you not 

agreeing to pay taxes. My suspicion is, is that you 
probably do pay your taxes . 

And so the thing is, is I think there's a difference 
between being the figurehead that he is within NXIVM 
Corporation in front of a group of people saying that -- 
saying things about not agreeing to pay taxes and things 
like that has a whole different meaning than if you and I 
were -- just sat down to have lunch and, you know, 
complained about the tax structure in the United States . 

Q So you think that -- all right. 

A My experience is Barbara Jeske is -- she's an advocate of 
not paying taxes, and she's the top ranking student of 
NXIVM. 

Q Top ranking student? 

A That's my understanding. She's also on the executive 



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board -- or she's been on and off the executive board. 
She was also my field trainer. She's also been a head 
trainer, and she's -- when I left NXIVM was the highest 
ranking person. Like, I was a proctor. She was a senior 
counselor . 

Q Why do you think what Barbara Jeske believes is what is 
NXIVM ' s policy? 

A Because Barbara Jeske has been with Keith for years. She 

was with Keith in CBI. 
Q Okay. Because Barbara Jeske and Keith know each other, 

then you believe that NXIVM has adopted her views of 

government taxes? 
A No. I believe that Barbara Jeske has adopted Keith's 

views of taxes . 
Q Do you have any basis to believe that? 
A Just based on conversations I've had with her. 
Q With her? 
A Correct . 

Q Has she told you that this is what Keith believes -- 
A Yes . 

Q -- we don't pay taxes? 
A Yes . 

Q Have you ever spoken with or corresponded with Peter 

Skolnik? 
A I have talked to Peter. 



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Q How many times? 

A I don't know the exact number. Maybe five or six times. 

Q Have you had e-mails with him? 

A No, I have not had any e-mails with Peter Skolnik. 

Q Did he send you any e-mails? 

A No . 

Q Did you send him any e-mails? 

A No . 

Q Did you exchange documents with him? 

A No . 

Q What kind of things have you spoken with Mr. Skolnik 
about? 

A Just basic advice on -- because I don't have an attorney, 

just basic advice, mostly through text messages. 

Q He sends you text messages? 

A Yes . 

Q And where are those text messages today? 

A I delete every text message I get. 

Q Who is your provider? 

A Veri zon . 

Q And you've given me that cell phone number? 

A Yes . 

Q How many text messages do you think that Mr. Skolnik has 

sent you? 

A I have no idea . 



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Q And have you had text messages with Mr. Skolnik since 

NXIVM filed the adversary proceeding against you? 
A A few. 
Q On what topic? 

A On helping me with this because I don't have -- I've just 
asked him questions like, you know, do I have to bring my 
attorney's e-mails? 

Because I believe you demanded those. You said, 
"Bring everything." 

Even when I said not -- "Do I have to bring my 
attorneys e-mails?" 

You said, "Bring everything." 

And I said, "But I believe that those are 
confidential . " 

And you said, "Bring everything. I'll look at them, 
and then you can call the judge," which I believe was 
kind of a trick to get those submitted as evidence and 
then I would no longer have my confidentiality -- 
Q Yeah. 

A -- based on that. So -- 

Q So you think I told you that I'd look at them? 
A Yes . 

Q That's what you told Mr. Skolnik; right? 

A No. I just asked him do I need to bring them. 

Q And so basically, Mr. Skolnik was telling you how to 



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respond to a document production? 
A No. He just -- he just said, "You do not have to provide 

those." That's all he said. 
Q How did you know to contact him? 
A I talked to him shortly after I left. 
Q Left what? 
A NXIVM. 

Q And who contacted whom? 

A I think Kim contact -- sent him an e-mail, and then he 
asked if he could do a conference call with us. 

Q And what -- and how long was that conference call? 

A I have no idea. That was a year and a half ago. 

Q And what was discussed in that conference call? 

A If we knew anything about the cruise ship ordeal, where 
it's believed that Kristin Keefee had tried to hire 
somebody to pose as some -- to pose as the mother and 
daughter of somebody to -- 

Q Yeah, I know the cruise ship. 

A Yeah. 

Q What else? 

A That's what I remember the most. And I -- everything 

that I know about that is just hearsay. 
Q Well, has he -- Mr. Skolnik asked you about details about 

how NXIVM ran its operations? 
A No . 



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Q Did he ask you questions about NXIVM's relationships with 

its attorneys? 
A No . 

Q So what prompted the most recent communications with 
Mr. Skolnik? 

A I just -- the recent one was do I have to bring those 

e-mails. I don't have an attorney. I asked for this to 
be postponed until I could find pro bono. The judge 
decided for whatever reason not to allow that to happen, 
and so I believe that -- I believe that I need to be 
protected because I believe that you will ask me 
questions that if I had an attorney in here the attorneys 
would say "Don't answer that." 

Q Do you remember you filed materials with the bankruptcy 
court saying that I was a screamer and a shouter and 
wouldn't let witnesses go to the bathroom? 

A I don't remember saying that you wouldn't let witnesses 
go to the bathroom. 

Q You did. 

A Oh, well, I apologize for that. 

Q Where did you get that information from? 

A From Barbara Bouchey's first experience with you deposing 
her . 

Q And you said that I pounded tables and screamed and 
shouted . 



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A That was my understanding. 
Q She told you that? 

A I don't know if she said that you pounded on tables. I 
believe she said that you screamed at her, that she 
couldn't go call her attorney, that she couldn't take a 
break, that she had no right to call her attorney and ask 
him to come in . 

Q She told you all of that? 

A Yes . 

Q When is the last time you had a communication with 

Mr. Peter Skolnik? 
A Last night about the do I need to bring my e-mails. 
Q And what did he say? 

A He said no. He said those are confidential and that you 

had no right to ask me for those. 
Q Have you ever spoken with Ford Greene? 

A No. The only -- well, let me take that back. The only 
time that I ever spoke to Ford is, is that when Barbara 
first went to meet him to see if she wanted to hire him, 
I was actually with her. I did not speak to him, except 
she forgot her phone charger in his office. And she was 
on a phone call, and I said, "I'll run back and get it." 

And he noticed the phone charger was there. He was 
bringing it outside the office, and I was going back. 
And all he did was hand it to me, and I said, "Thank 



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you . " 

Q So you traveled to Marin County with Barbara Bouchey? 

A Yes . 

Q And you sat in meetings with Ford Greene? 

A No . 

Q You did not? 

A No. No. I sat in the car and waited because his office 

did not have a separate office. 

Q And how long was the meeting? 

A I have no idea . 

Q So you've had no communications of substance with 

Mr. Ford Greene? 

A No . 

Q How about text messages? 

A No . 

Q How about e-mails? 

A No . 

Q How about uploaded or downloaded Google documents? 

A No . 

Q Have you ever spoken with a John Tigue? 

A No . 

Q Do you know who I'm talking about? 

A Yes . 

Q Have you ever e-mailed to him? 

A No . 



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Q You've posted on his blog, though? 
A Yes . 

Q Why do you post on his blog? 

A I posted on his blog because a lot of people that were 
coming to the blog -- I was a reader of the blog, and a 
lot of people were coming to the blog not understanding 
how people could be so stupid to get sucked into the 
cul t . 

And so what I did was I posted my personal 
experience of how I got involved and how I stayed so long 
based on that so that family members could understand my 
experience and what I believed to be true of how people 
could get -- could get, you know, involved in a company 
that behaves the way that NXIVM behaves . 

Q And you produced all of your blog printouts? 

A Yes. As far as I could -- as far as I know, I did. 

Q And where can I find the start of your blog printouts in 
your -- 

A Pardon? 

Q -- production? 

In your document production, where does your blog 
printout start? 

A It ' s in its own little -- I stapled all of those 
together, so it looks like this. (Indicating.) 

Q All right. 



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A Yeah, it won't be in that one. It's just a little -- a 

little -- 
Q One little thing, huh? 
A Yeah, one little thing. So -- 
Q Hold on. 

A Do you want this back? 

Q Yeah. Well, hold on to it. 

A Okay. 

Q Let me see if I can find this blog thing. 

A Do you mind while you're looking for that if I run to the 

bathroom real quick? 
Q That's fine. 

THE VIDEOGRAPHER : As we go off the 
record, the time is 1:35. 

(Recess 1:35 - 1:37 p.m.) 

THE VIDEOGRAPHER: We are back on the 
record. The time is 1:37. 

EXAMINATION (Continuing) 

BY MR. CROCKETT : 
Q Do you know the names of any of the persons who posted to 

the blog other than Mr. Tigue and yourself? 
A I've seen Becca Friedman on there a few times. Other 



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than that, I don't know any -- I don't even actually know 
Becca personally. And I don't know anybody else. 
Q And does she post with her real name? 

A From what I -- what I've seen, she posts with her real 
name. If she posts other than that, I don't know. 

Q Have you ever spoken with -- well, you have mentioned 
that -- Joe O'Hara? 

A Yes . 

Q About how many times? 

A Quite a few times. I don't know. I don't know how to 
guesstimate. Maybe 50 times. I don't know. 

Q Do you communicate through him -- with him with text 
messages ? 

A Not very often. 

Q Did you -- have you spoken with Mr. Skolnik in the past 

week by text message? 
A I told you I did last night. 

Q Yeah. Is there a reason why you didn't produce those 

text messages today? 
A You didn't ask for text messages, nor do I know even how 

to produce a text message. 
Q All e-mails, correspondence, and written communications, 

you don't consider text messages to be that? 
A I didn't make that assumption. 
Q Are they on your phone now? 



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A Probably not. I delete everything. 

Q Can you check your phone and tell me if you can see any 

e-mails from Mr. Skolnik? 
A Okay. 

Q And if so, I'd like to see them. I mean text messages. 
A Nope. There are none. 

Q How about from anybody else, like Tigue, O'Hara -- 
A I don't -- I have never communicated with John 

Tigues [ sic ] . 
Q Okay. O'Hara? 
A Nope . 

Q When did you delete Mr. Skolnik' s text messages? 

A The one I deleted last night was the one he sent me in 
regards to my question of did I have to provide my 
attorney's e-mails to you. 

Q And what other text messages have you deleted of his? 

A I don't recall that. It's just been general questions 

about -- questions I've had, you know, in regards to "Can 
I file a motion?" You know, like when this deposition 
was set up and I knew I wasn't going to probably have an 
attorney by then, you know, "What do I do? Do I file a 
motion? What do I do in regards to that?" 

And he didn't even really know how to answer that. 
I actually spent more time asking the court clerk 
procedural questions . 



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Q Have you asked Mr. Skolnik about NXIVM's claims about 

intellectual property? 
A No . 

Q Have you provided him information about the video link? 
A No. My understanding is that he subpoenaed those videos 

from Barbara Bouchey. 
Q Where did you get that understanding from? 
A Barbara Bouchey. 

Q And Barbara Bouchey said she turned over those videos to 
Mr. Skolnik? 

A She said he subpoenaed them. Whether she turned them 

over or not, I don't know. 
Q And that's the three-day video, the -- 
A Yes . 

Q Okay. Do you know if Mr. Skolnik had any role in getting 

the video posted on a Russian server? 
A No . 

Q Do you know -- 

A I don ' t know that . 

Q Do you know who had a role in getting the video posted on 

a Russian server? 
A No, I don't know that. 
Q You know it's on a Russian server? 
A I saw that on John Tigue ' s blog. 

Q And do you know how your YouTube video got put on a 



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Russian server? 

A I don't know that, nor do I know how it got to the New 
York Post. I think my e-mail was very clear to ask 
people to not do anything with that video unless 
something happened to me or something happened to 
somebody that had been -- that I considered in danger. 

Q You really think NXIVM would do you physical violence? 

A At this particular junction, when -- juncture, with all 
of the stuff that I have uncovered, I believe that as I 
started to -- like the tax thing with the State of 
Washington, I didn't know what Keith would do. 

Q What is the best piece of evidence that you think you 
have which suggests that NXIVM might do you physical 
violence ? 

A The best piece of evidence that I have is my 

understanding of the escalation of the abuse cycle. 
Q What does that mean? 

A Well, that when you take somebody who is what 

psychologically is considered an abuser, somebody who 
lies and manipulates, especially to women, and then does 
the control stuff that he does, is, is that unchecked 
that that can actually escalate into an abuse cycle that 
is -- could take somebody's life. 

Q And that's your best basis for believing that NXIVM would 
do you physical harm? 



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A I'm scared . 

Q And that's it, because you think that -- you believe 

that — 
A I mean -- 
Q Let me finish. 
A Okay. 

Q And so you believe that your physical life is in danger 
because you've been told that Keith Raniere has sex with 
different women? 

A Not just that. I think it's the manipulation that takes 
place around that. I think it's the manipulation that 
takes place within the upper leadership of NXIVM. I 
think it ' s because of the lies and the cover-ups that 
I've been told that I've found out are not necessarily 
the truth. It's how I see how they treat people within 
the organization, especially people who won't kowtow to 
NXIVM' s policies in regards to that. 

And so I believe, based on my studies in graduate 
school, that there is an -- there is an escalation of the 
abuse cycle, and I am concerned about that. 

Q What do you think is the biggest lie or whopper that 
NXIVM' s ever told you? 

A I think that -- I think probably one of the most damaging 
lies was, is that -- well, a couple of different things. 
One, lying about people, one about Barbara Bouchey being 



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a full suppressive, based on the fact that they teach a 
module based on that, and telling me that she's crazy to 
influence how I would be around her, and I think that 
that was used as a way to keep me away from ever 
believing anything that she ever said. 

I also think that how they've lied about other 
people who have left -- everybody that's left, it's 
always been their fault and nothing within the 
leadership's fault. I think them covering up the fact 
that Keith is -- behaves in certain ways that people find 
morally and ethically not acceptable are big lies that 
they've told. I think that Nancy lying, or whoever did 
to the Washington State Department of Revenue, about 
licensing their program to third-party people -- those 
kinds of things all lead me to believe that there's a 
cycle of abuse that takes place. 

Q So who told you the whopper about Barbara Bouchey being a 
suppressive ? 

A Nancy Salzman. 

Q I notice that was the biggest lie -- the first lie that 
you mentioned, that Barbara Bouchey was a suppressive; 
right? 

A That what? 

Q Couldn't that just be somebody's opinion? I mean, "I 

think so-and-so is a suppressive. I think that person's 



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got a suppressive personality," you think that's a lie? 
A I think for the leader, the president of a company, to go 

around and tell people that about other people when they 

teach that particular module is a setup in regards to 

that . 
Q All right. 

A Why would somebody -- why would somebody that runs a 

company based on human potential and human behavior that 
teaches an entire two-hour module on they call the fall 
that deals with the downfall of somebody who's 
suppressive go around and speak that to anybody in their 
company about that? 

Q So another big whopper you said you heard was that Keith 
lied about his sexual relations . Have you ever heard 
NXIVM teach a course to the effect that the founder of 
NXIVM is celibate? 

A They don ' t teach a course on that . 

Q Have you ever heard a course taught to the effect that 

the founder of NXIVM is monogamous? 
A They don't teach that either. 

Q So when you say that Keith Raniere lied about his sexual 
relationships with women, where did he say he was 
monogamous or celibate on the one hand, and how did you 
learn that that was a lie? 

A Well, my understanding is, is that he told people that he 



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was involved with that he was monogamous . 
Q Where did you get that information from? 

A I got that from both Barbara Bouchey and Toni Natalie. 
Q Ex-girlfriends. All right. 
A Well, okay. So -- 

Q So you also -- so based upon information you got from 

ex-girlfriends -- 
A Well, it's not just ex-girlfriends, though. 
Q Okay. Well, that's -- I'm just going on what you're 

telling me, ex-girlfriends. 
A Well, but I also -- but I also pointed out that there was 

a situation with Keith and Kathy Ethier that I believe 

was inappropriate. 
Q Right. 

A And then there was a situation with Angela Ucci that I 

believe was inappropriate. 
Q Where he made moves on them? 
A Right. 

Q Yeah. So you -- so basically, it's your position because 
Keith had sexual relations with these two different women 
and made moves on two others that your life's in danger? 

A No. It's more than that. I think that there's a cycle 
of abuse . I think the way that he works women to not 
talk about it and then when they do find out about the 
fact that he's having sexual relationships with other 



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women how a group of other women come in -- Nancy 
Salzman, Pam Cafritz, Lauren Salzman -- they come in to 
work that person's issues and attachments around 
ownership of Keith. 

"Do you own Keith's penis?" "What's the difference 
between Keith sleeping with somebody versus playing the 
violin?" Those kinds of things are all manipulative. 
Q Has Keith ever come on to you? 

A He knows I'm a lesbian, so he wouldn't do that. 
Q Has he ever slept with you? 
A No . 

Q Has he ever tried to manipulate you sexually? 
A No . 

Q So because Keith sleeps with other women and makes the 
moves on other women, you feel like your life is in 
danger; is that right? 

A I believe it's part of the cycle of abuse. 

Q Okay. 

A And so I believe that it's very possible that my life is 
in danger. I mean, I've had strange cars parked across 
my house, all different kinds of stuff. 

Q And were those strange cars parked across from your house 
NXIVM cars? 

A No, but I believe that they have hired Pis before to 
harass people. 



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Q Have you ever been harassed by a PI? 
A No, but I have friends who have been. 

Q Who told you that they were harassed by a NXIVM-hired PI? 
A Angela Ucci, Nina Cowell, Barbara Bouchey's personal 

assistant, Mel, Melanie. I don't know her last name. 

Button, I think, is her last name. I don't know if I 

mentioned Angela Ucci. 
Q Who -- 
A Kathy Ethier. 

Q Who was the private investigator? 

A I know him as Steve Rambam, who went around presenting 
himself as an -- what did he say he was? -- an 
investigator for the state of New York, which is very 
different than "I'm a private investigator licensed in 
the state of New York. 

Q Is that what he told you? 

A Not me . 

Q So you got the information from other people? 
A Several people . 

Q All right. Have you ever spoken with Chet Harding? 
A No . 

Q Ever e-mailed or texted to him? 
A No . 

Q Have you exchanged text messages with Toni Natalie? 
A Yes . 



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Q Have you deleted all of those? 
A Yes . 

Q And when was the last time you exchanged a text message 

with Toni Natalie? 
A This morning. 

Q And you've already deleted it? 

A I delete all of my texts when they come in except for 

certain people . 
Q Even though you knew that you had a subpoena for them, 

you deleted them? 
A I didn't know that the subpoena required text messages. 

There's nothing in there that says texts. I would assume 

that if you wanted texts you would have said texts . 
Q But the messages concerned NXIVM; correct? 

A No. This morning it was about, you know, just a support 

of me coming here. It wasn't about NXIVM. 
Q All right. 

A Most of the stuff we text back and forth has nothing to 

do with NXIVM. 
Q Okay. 

A It's just our personal relationship with each other. 
Q Have you spoken with Jim Odato? 
A Yes . 

Q And you showed -- 

A You know that I have. It stated that in my -- 



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Q Well, I still get to ask you the questions. 
A Okay. 

Q I know a lot of things, but I still have to ask the 

questions . 
A Okay. All righty. 

Q Now -- and did you display your little video to 
Mr. Odato? 

A He did -- he did have -- just day one and a part of day 

three, which I've asked him to destroy. 
Q And have you spoken with a Vanity Fair reporter? 
A Yes, I did. 

Q Do you remember her name? 
A Suzanna Andrews . 

Q And how much time did you spend with Suzanna Andrews? 

A I have no idea . Maybe an hour . 

Q Did you discuss the video with her? 

A I don't recall discussing the video with her, nor did 

I -- nor did she have a copy of it. 
Q Did Jim Odato say what he was going to do with the video? 
A He wanted -- he -- I believed that I was giving it to him 

as background information. He wanted to do a story on 

that, and I refused to let him do that. 
Q He did a story on that . 

A Not on the video, that I recall. He might have done it 
on the one that -- on the segment that got -- became 



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public, but that was through no direct doing on my part. 
Q The segment that became public, have you seen that one? 
A The -- yeah, I've seen that. I sent that out to -- the 

link to that out to my friends and some of my -- well, my 

sister . 

Q The segment that became public is kind of odd because 

it's got the faces of women blurred out. 
A Right. 
Q You did that? 
A Yes, I did. 

Q So the segment that became public is your segment; right? 

A Correct. But I didn't send it to Jim, nor did I send it 
to anybody else in the press. I sent that to my friends 
and asked them to keep that, that if anything happened to 
me or to anybody else, like Barbara Bouchey, that they 
use that as evidence if it looked fishy. 

Q So if one of you were, like, killed, like Ronni Chasen in 
Beverly Hills -- 

A I don't -- 

Q Oh, it's a big deal in Beverly Hills. 
A Oh . 

Q So if one of you were killed by some assassin, that you'd 

be able to release this video; right? 
A Not release it, but to give it to the authorities. 
Q Yeah. And so have you had discussions with law 



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enforcement authorities expressing your fears that you're 
about to be assassinated? 

A No, I haven't. I know John Tigues [sic] has, and I know 
that he's been threatened -- what perceives to be 
threatened several times . And what scared me the most in 
relationship to that and I believe was an escalation of 
the cycle of abuse is when he -- somebody called the 
state troopers on him. 

Q Do you have any evidence that NXIVM had any role in -- 
well, the state troopers, that's when he tried to crash 
Vanguard week; right? 

A I believe that he went there. 

Q Yeah. He tried to crash a private party, and he wouldn't 
leave, and NXIVM had no choice but to call the troopers 
out. What's wrong with that? 

A The thing is that why call the troopers? He did leave. 

Q Only after the troopers came. 

A No. He was -- my understanding -- 

Q All right. 

A -- from what he posted on the blog is that he had already 

left the confines of that place. 
Q Yeah. All right. All right. Let's -- what -- in your 

letter to Keith and Nancy dated April 24, 2009 -- it's 

Exhibit I . 
A Okay. 



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Q -- you've got a paragraph in there that's the second one. 
"As we compared our data of why the system wasn't 
working, we identified evidence of secrecy, 
nondisclosure, and lack of transparency." 

Now, is it correct to say that when you wrote -- 
authorized this letter's release that you were basically 
summarizing all of your concerns and problems with NXIVM? 

A Actually, my understanding of this is, is that it was 
Keith's behavior, that had that been made public 
knowledge, that people would make different decisions 
about choosing whether to go with the company or not. I 
mean, some -- I believe some people don't care about 
that . 

Q Well, let's look at the letter that you sent on April 24, 
2009. This is a letter, again, that you partially 
authorized; correct? 

A I didn't write it, but -- 

Q You authorized it? 

A -- I was involved -- there was several hours of 

conversations about what to write. 
Q So a lot of time and effort went into what this letter 

should say; correct? 
A That's my understanding, yes. 

Q And so looking back at this letter today, you think that 
this letter is probably the most accurate statement of 



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what your concerns and complaints were about NXIVM and 

Keith Raniere; correct? 
A You know, the -- 
Q Correct or not correct? 

A Well, the thing is I haven't looked at the letter -- 

Q Look at it . 

A -- for a very long time. 

Q I want to know if this letter is what you think back then 
was the most accurate statement of your beefs about NXIVM 
and Raniere after spending several hours working on it . 

A Okay. 

Okay. Well, I have already mentioned that I did not 
understand that this was being sent out in relationship 
to the money being paid or we would go to the press. I 
thought it was to say that if we didn't receive a 
response from NXIVM that we would go to the press . And 
the reality is, is that we did receive a response, and 
none of us went to the press about our resignation. 

Q But other than that, the contents of this letter was 
something that you worked on for hours; correct? 

A Yeah. My understanding about this letter is, is that the 
issues that we had with this is, is that because the 
women that were identified that Keith was having a 
relationship with -- except for Nancy Salzman and 
possibly Sara Bronfman and obviously Edgar Boone, Keith 



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was sleeping with all of the women on the board -- 
Q Well -- 

A -- which I believed was a conflict of interest. 

Q I guess I'm sort of wondering why you don't mention 

Keith's sexual relations in here, why you don't mention 
his compulsive gambling, why you don't mention the fears 
of assassination, why none of that is mentioned in this 
letter . 

A I don ' t know that . 

Q You talk about -- you've got a sentence in there that 

says, "As we compared our data of why the system wasn't 
working, we identified evidence of secrecy, 
nondisclosure, and lack of transparency." 

A Correct . 

Q Do you see that? 

A Right. 

Q Was it your understanding that NXIVM operated on the 

basis of secrecy? 
A In regards to Keith's sexual and gambling behavior, yes. 
Q It doesn't say anything about sexual and gambling 

behavior. It just says the system wasn't working. 
A Because of those two things. For me, because of those 

two things . That was the main culprit in why the system 

wasn't working. 

Q Why didn ' t you come out and say what your concerns were 



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other than just refer vaguely to why the system wasn't 
working, inconsistencies, conflict of interest? I mean, 
why didn't you -- why didn't you just come out right and 
say what you've been saying today, that you feared -- 
that you were fearful of getting killed? 

A That came later. 

Q I see . 

A The fear of that was really understanding the lengths 

that I believe that NXIVM has gone through to hide in -- 
certain behaviors that they do and the escalation that I 
know of the cycle of abuse . I think that I have a pretty 
good understanding of domestic violence, and I believe 
that what I -- and my opinion is, is that NXIVM as an 
organization is just a macrocosm of domestic violence. 

Q So give me the best example you can of a NXIVM leader 
inflicting domestic violence on a NXIVM student or 
client . 

A Okay. A couple of examples of that would be the 

emotional abuse that takes place within the organization. 

Q Let's talk about physical abuse. I mean, you're talking 
about murder, and so I want to know, do you have a good 
example of where a NXIVM leader -- 

A Physical -- 

Q -- inflicted physical violence on somebody? 
A Physical abuse is just one of the spectrums . 



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Q No. No. Help me out here. Humor me. Tell me, are you 

aware of any evidence -- 
A You have -- the question you asked me is to give you 

examples of domestic violence. 
Q Well, no. Here's the question. I'm not asking that 

question. I want to know are you aware of any evidence 

of physical violence inflicted upon one NXIVM member by a 

NXIVM leader? 

A I don't believe that physical violence needs to take 

place in order for there to be domestic violence. 
Q Try and answer the question. 
A I have -- 

Q Are you aware of any incident of physical violence? 
A Not of physical violence. 

Q Are you aware of a NXIVM leader like Keith Raniere 

saying, "If you don't do this, I will come and beat you 
with a baseball bat" or something to that effect? 

A Well, no. The only example that I have of that is that 
in that clip of the video that I sent out, Barbara 
Bouchey questions Keith's leadership ability, and then 
right after that he pauses and he says, "I've -- people 
have been killed for my beliefs, and I've had people 
killed. " 

That, to me, is a sign of a microcosm of what I 
would consider domestic violence but on a larger scale. 



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Q Have you ever heard Keith say that in any NXIVM-related 

meeting, "I've had people killed"? 
A No . 

Q Have you ever heard anybody say, "You know, Keith 
Raniere, he talks about having people killed"? 

A That was the first time I had ever heard that. 

Q Have you ever heard anybody in any NXIVM meeting even 
refer obliquely to threats of physical violence? 

A I -- and I've said that. I've already said that I don't 
believe that there has been any threats of physical 
violence, but I believe that my understanding of domestic 
violence is, is that's one of the last resolves. 

Q So it may be one of the last resolves, but you haven't 
seen any indication at all -- 

A Not physical -- 

Q -- that there's been physical violence, have you? 
A Not physical violence, but I believe that there is 

emotional violence that takes place, and I also think 

that there's financial violence that takes place. 
Q What's the worst form of emotional violence that's been 

inflicted upon you by NXIVM? 
A I think Nancy Salzman sitting in my living room telling 

me that she and Keith belive that I was a full 

suppressive . 

Q That's a -- is that a really nasty thing to call 



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somebody -- 
A Yes . 

Q --a suppressive? 

A Yes. In NXIVM, what that means is you've lost your 

conscience. You're a psychopath. So that's a pretty 
damning thing. 

THE REPORTER: Hold on. 
THE VIDEOGRAPHER : As we go off the 
record with permission of Counsel, the time is 2:04. 

(Pause in proceedings.) 

THE VIDEOGRAPHER: We're back on the 

record. The time is 2:05. 
Q (By Mr. Crockett) Is one of the reasons you believe your 

confidentiality agreement to be invalid is because nobody 

signed it on the -- on NXIVM' s side? 
A My -- my limited understanding of contracts is, is that 

it should be signed by all parties. 
Q So even -- so because yours wasn't signed, you believe 

you're not bound by the confidentiality agreement. 
A Well, I don't even know if that's mine, but -- 
Q Well, so let me rephrase the question. 

So do you believe you're not bound by any 

confidentiality agreement because you're not certain 

whether you've actually been presented one that shows 



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your signature? 

A Well, actually, I have signed and we've already attested 

to that I have signed the applications. So if anything, 

I'm bound by those. 
Q Well, I'm asking you if you think you're -- if 

fundamentally you believe that you're bound by the long 

form confidentiality agreement. 
A I don't understand why somebody would provide an 

agreement -- 
Q That's not my question. 
A Well -- 

Q Do you think you're bound by that? 

A If it is my confidentiality agreement and if it's proven 
that that ' s my signature and it ' s proven that that is the 
actual confidentiality agreement that was produced that 
day, then yes, I do believe that I'm bound by that. 

Q Well, let's operate off the assumption that we just can't 
find your confidentiality agreement. Do you believe that 
you're not bound by the long form confidentiality 
agreement ? 

A I would like to see which one I signed. 
Q Let's say that we can't find it. 

A Then I believe that NXIVM doesn't have a contract with 
me . 

Q Okay. So even though as a NXIVM officer you made sure 



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that your students and your clients signed those and even 
though you knew that members of the Tacoma staff would 
transmit those documents to NXIVM, you personally feel 
that you're not bound by a confidentiality agreement 
unless you're convinced that you actually signed one; 
correct ? 

A I belive I'm not bound by it, but that doesn't mean that 
I wouldn't uphold it. The thing is, is that I have not 
done anything with their intellectual properties. I've 
kept them in safekeeping. I've tried several times to 
return their intellectual properties. I do believe 
beyond that I do have first amendment rights . 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) I think my question is -- I don't want 
filibustering and lecturing coming from you. I just want 
to know this. If you are convinced that you didn't sign 
the long form confidentiality agreement, is it your 
position that you're not bound by NXIVM' s confidentiality 
policies ? 

A Well, I have signed the application, so I am bound by 
that. In regards to the rest of the confidentiality 
agreement, I'm not a contract attorney. I don't have an 
attorney present, and I think that that would be up for 
either a court or a contract attorney to answer. 



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Q Then if you're bound by a confidentiality agreement as to 
NXIVM's confidential materials, why would you spend so 
much time talking to reporters about NXIVM's operations? 

A I don't believe I've talked to reporters about NXIVM's 
operations. I believe that I've talked to reporters 
about Keith and Nancy's personal behavior, which I don't 
believe is -- that I'm bound by, by the confidentiality 
agreement . 

Q What NXIVM members who have left NXIVM have received 
actual death threats? 

A I -- Joe O'Hara had -- from -- had "You will be dead in 
seven days" spay -- spray painted on a house that he was 
having built. Toni Natalie's mother, from my 
understanding, was told by Keith that "We ' 11 either see 
her dead or in jail." Yuri Plyam was -- his wife was 
told that "Yuri will be swimming with the fishies in 
seven days." John Tigues [sic], I believe, has had death 
threats . 

Q Who told you that Joe O'Hara had spray painted -- 
A Joe . 

Q Did you see the spray paint yourself? 
A No . 

Q Did you see pictures of it? 
A No . 

Q Did he tell you how he thought NXIVM was responsible? 



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A Yes . 

Q What was -- what did he say? 

A He just said that it happened while he was going through 

all of this -- his legal battles with them. 
Q Did he say that he saw a NXIVM person do it? 
A No, he didn't say that. 
Q Was it signed by a NXIVM person? 
A No . 

Q Now, the death threat communicated to Toni Natalie's 

mother, did you hear or see Keith Raniere make that death 
threat? 

A No . 

Q So this is something Toni Natalie told you or her mother? 
A Toni Natalie told me. 

Q So a former girlfriend told you that -- a former Raniere 
girlfriend told you that her mother had been threatened 
by Keith? 

A Correct . 

Q And so you mentioned Natalia [sic] Plyam. Did you get 

that from Natalia herself? 
A No. Yuri told me. 

Q And who else did you mention had been threatened? 
A John Tigues. It's -- he writes about it on his blog. 
Q And did he indicate how he knew NXIVM had made a death 
threat? 



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A I think it's written on his blog that he believes he was 
ran off the road, that, you know, they called the cops 
and told that he was a terrorist, those different kinds 
of things. All of those things are on his blog. 

So if one person told me that, I could easily 
dismiss it, but when four people tell me through four 
different mediums that this happened, I believe that 
that's a pattern, and I believe that that's a pattern of 
what I would call violence. 

Q Now, when you showed the video to Jim Odato, where did 
you meet him? 

A I didn't meet him. 

Q How did you show him the video? 

A I provided him with a link to the day three one, and then 
the other thing is, is that on the day one is that I 
e-mailed him a link for that. 

Q So you posted multiple videos on YouTube? 

A No, just that one. The only one that I have on YouTube 
is the one that's on there. And again, that's in a 
private setting, and the only reason I haven't taken it 
off is I was asked not to destroy anything. Otherwise, I 
would take it off. 

Q The materials that you've held onto, are they sufficient 
to run a center, a NXIVM center? 

A I believe so. And that was my main reason why I asked 



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why I couldn't give these to Wendy Rosen-Brooks or 
Charmel Bowden. I asked NXIVM's attorneys. 

MR. CROCKETT: Move to strike as 
nonrespons i ve after your first sentence. 

Q (By Mr. Crockett) In your declaration, you have a 

sentence that doesn't make any sense. I'll read it to 
you. "It is possible that it is current NXIVM members in 
an attempt to frame their whistleblowers . " Do you know 
what that meant? 

A Could you read that again? 

Q "It is possible that it is current NXIVM members in an 

attempt to frame their whistleblowers." 
A Can you show me where that is so I can read it? What 

page ? 

Q That's Page 19, and it's Subparagraph C, the last 
sentence . 

A Oh, okay. Well, one of the things that NXIVM put in 
their complaint against me is that I had been 
disseminating information, NXIVM's materials. And so 
what I believe is that there have been thousands of 
students that have gone through, and it could be any one 
of those that have disseminated information to the press 
regarding their materials, and that I believe that it is 
even possible that it's one of the current NXIVM members 
that has disseminated that information just so that NXIVM 



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could come in and say in my bankruptcy court that it was 
me who disseminated that information, to frame me -- 

Q Do you have any -- 

A --in doing so . 

Q -- proof of that? 

A It's just a hypothesis. 

Q Do you have any proof of that? 

A No . 

Q And then you say on the same page: "The facts are it was 
common knowledge that the copyright materials, tapes, 
notes, DVDs, and files were unlocked at the Albany 
training center in the hallway" -- 

A Where -- 

Q -- "accessible to anyone for almost eight years before 

they decided to put them in a locked room." 
A Okay. What page are you on again? 
Q Same page, Page 19 -- 
A 19 . 

Q -- Subparagraph D. 
A Okay. 

Q What's the basis for your knowledge that NXIVM left their 
intellectual property in an unlocked area? 

A My personal experience. I would -- I spent a lot of time 
at the NXIVM center in Albany, New York, and experienced 
that it was kept unlocked. And then when they did lock 



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it up, everybody knew where the key for that was. And 

then there were several times that even after they moved 

them to a locked room that that room would be unlocked 

and left unattended. 
Q And -- but the persons who would have access to those 

unlocked rooms would be NXIVM officers; correct? 
A No. It would be anybody that was in the building. 
Q Do you have any basis to believe that NXIVM material was 

stolen by a former coach or trainer and published on the 

internet ? 

A I don't have any knowledge of that. It's just a 

hypothesis. They're in their complaint blaming me of 
that, and so I'm just pointing out how it is possible 
that it's other people because I know I didn't do it. 

Q In your complaint, you say that the -- that something you 
call the World Intellectual Property Organization denied 
Keith Raniere ' s patent claims. Where did you get that 
information ? 

A It's on their website. 

Q Whose website? 

A The World Intellectual Property Organization's website. 
Q You found that yourself? 

A Actually, it was -- I found that actually before I left 
NXIVM just based on some -- it was on a blog site. I 
think it was Kristin Kreuk's blog site, and it's actually 



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Exhibit H in my answer to their claims. It's Exhibit H. 
It talks about -- on Page 3 of that, it talks about the 
Claims 1 through 18 were denied, and on Page 4. Plus, a 
240-page manual of NXIVM's material has been made public 
domain for download. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) Do you believe that you shouldn't have 

to turn over NXIVM's client list because NXIVM's clients 

were defrauded by Keith Raniere? 
A No. I don't believe that I have a NXIVM client list, but 

I am more than willing to give them the list that I put 

together, which was my property. 
Q That you developed while you were a NXIVM trainer; 

correct ? 

A Correct. I don't -- the list has no meaning for me, so 
there's no reason for me to hang on to it. 

Q You say in your declaration that Rational Inquiry 

trainings are used as a venue to stalk students who might 
fit into Raniere ' s profile of sexual conquests. 

A What page are you on? 

Q It's Page 29. 

A And which paragraph? Which -- 

Q 110 . 

A Okay. 110. 



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Q You say that, again, "Rational Inquiry trainings are used 
as a venue to stalk their students to who might fit into 
Raniere ' s profile of sexual conquests and who might be 
willing to give Raniere money." Do you have any basis to 
support that claim? 

A Well, based on the number of women that I suspected that 
Keith Raniere had sexual relationships with before the 
April meetings, pretty much everybody I suspected that he 
had sexual relationships with was verified by Barbara 
Bouchey that he had had sexual relationships with them. 
Some people I suspected that he had sexual relationships 
with, Barbara Bouchey did not know. 

And just based on the fact that these women were 
made what I believe would be identified as special within 
the curriculum. And the same thing with -- anytime 
anybody with any financial means came into the company, 
they were automatically considered a VIP within the 
trainings and given VIP status. 

Q I guess that's pretty terrible, to give wealthy clients 
VIP status? 

A Well, it's not that it's necessarily a terrible thing 
done under the right guides, but my -- several 
conversations I've had with Nancy Salzman is, is that 
they're constantly looking for money. 

Q I guess that's a terrible thing for businesses to 



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constantly look for money? 
A Not necessarily, but when you take $70 million and you 

lose it in the commodities market, that to me is a 

terrible thing. 
Q Who lost the $70 million? 
A My understanding is Keith Raniere did. 
Q His money? 
A No . 

Q How can he lose $70 million he didn't own? 
A Because he borrowed it, I guess -- 
Q From who? 

A -- or people gave it to him. 
Q People gave it to him, huh? 

A Which I think is a conflict of interest based on his 
position in the company. 

Q Who do you think gave him the $70 million? 

A I think that Barbara Bouchey gave him money. I think 
that Pam Cafritz gave him money. I think that Karen 
Unterreiner gave him money. I think that Sara and Clare 
Bronfman gave him money. I believe that -- who else? -- 
Michael Sutton gave him money. 

Q Okay. Which of these people told you that, that they 
gave him money? 

A Just, well, Barbara Bouchey and Yuri Plyam. 

Q So what women have actually told you that they've slept 



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with Keith Raniere? 
A Toni Natalie and Barbara Bouchey -- 
Q That's — 

A -- and Esther Chiappone. 
Q Three people? 
A Yes . 

Q And so you sort of -- let's go off the record. 
A No, I don't want to have anything off the record. 
Q We have to because we have to change the tape. 
A Okay. All right. Sorry. 

THE VIDEOGRAPHER : As we go off the 

record then, this is the end of Disk No. 2. The time is 

2:22. 

(Recess 2:22 - 2:28 p.m.) 

THE VIDEOGRAPHER: We are back on the 
record. This is the beginning of Disk No. 3. The time 
is 2:28. Please proceed. 

EXAMINATION (Continuing) 

BY MR. CROCKETT : 
Q Did you talk to a producer from the Dr. Phil Show about 

NXIVM? 
A Yes. They called. 



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Q Did they initiate the call to you? 
A Yes . 

Q Did they tell you how they got your name? 

A I didn't ask them, and they didn't tell me. 

Q Who was the person you talked to? 

A Andy. Andy. 

Q What did Andy want? 

A He wanted to know my story. They were -- I guess they 
were going to do a TV show. I spent -- I don't know -- 
about an hour and a half on the phone with him and never 
heard from him after that . 

Q When was that? 

A I'm not sure exactly of the date, but about four months 
ago . 

Q And what did you tell him about NXIVM? 

A I told him my experience, pretty much the same stuff that 

I put on the blog. 
Q Have you spoken to a reporter from 20/20? 
A Just briefly. 
Q Did that person call you? 
A Yes . 

Q You didn't initiate the call? 
A No . 

Q Did any -- did the 20/20 reporter tell you why -- who got 
them interested in NXIVM? 



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A He didn't tell me who got him interested, but my 

understanding is he ' s been interested for years now of 
doing a story on NXIVM. We probably spoke for maybe 
three to five minutes on the phone, and I have not heard 
back from him since. 

Q How long did you spend with the reporter from Vanity 
Fair? 

A I think I said that already. 
Q You can tell me again. 

A I don't know. An hour, around an hour. I don't 

remember . 
Q It was a telephone call? 
A Yes . 

Q Did you provide her any documents to look at? 
A No . 

Q Did she ask you to look at any documents? 
A No . 

Q How long did you spend speaking to the reporter from 

McClain ' s? 
A About 30 minutes. 

Q Did he or she provide you any information? 
A No documents . 

Q Did you provide that reporter any documents? 
A No . 

Q What was that reporter's name? 



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A I don ' t remember . 

Q Have you ever spoken with a reporter from the New York 
Post? 

A Real briefly when she did a story on my bankruptcy. 

Q And you sent the reporter a link to the video? 

A No. By that time, I think they had -- it had already 
been on the -- they had already done on the website. I 
did not provide the reporter from the New York Post with 
anything . 

Q So you know that -- but when the New York Post spoke to 
you, you realized or you knew that they had a copy of 
your video somehow; right? 

A I think that story had already -- had come out, and it 
was already on the blog. She was doing a story on my 
bankruptcy. And I didn't call her, nor did she call me. 
I actually happened to be on a phone conversation with 
Toni Nat al ie . 

Q So Toni Natalie was answering guestions, and you were 
just listening in? 

A No. Toni said that she had to -- she had an incoming 
call. She put me on hold. Then she came back on, and 
the reporter from the New York Post was on, asked me a 
couple of guestions, and I got off the phone call. 

Q Do you owe NXIVM money? 

A I believe I do . 



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Q How much? 

A I don't have any idea. 

Q If you believe you owe NXIVM money, then why were you 
trying to extort $250,000 from Keith Raniere? 

A That's NXIVM' s opinion that I was trying to extort money. 
I don't believe I was trying to extort money. 

Q Well, if you -- 

A I think that NXIVM teaches about value exchange, and what 
I was trying to do is just ask for value of the value 
that I had built. 

Q So you -- you believe that you owe NXIVM money, but when 
you threatened to go to the press, at the time you 
believe you were taking the position that they owed you 
$250,000; right? 

A I believe they owe me my April commissions, which was 
about $9,000, and I asked for a value exchange to be 
given. I recognized that I had no contract with NXIVM to 
protect me. All I did was ask. The offer -- my asking 
was refused, and I believe that that was my mistake for 
not getting a contract and not having a contract in 
place . 

Q Now, suppose all of the things that you were saying in 
your declaration were untrue about NXIVM and its crimes 
and misdemeanors, what do you think you ought to do to 
reverse the damage? Anything? 



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A I don't believe they are untrue, so I haven't even 
explored that. 

Q Do you have any personal claims that you think that you 

have against NXIVM? 
A Personal claims? 
Q Yes . 

A I don't understand what you mean by that. 

Q Like, do you claim anything against NXIVM? Any claims 
for money? Any claims for damage? 

A I haven't explored any damage claims. I do believe that 
they owe me my April commissions, which I believe are 
more than what they -- what I owed them for educational 
courses, but I don't know that for sure because I don't 
have that data. I've been -- was locked out from my page 
on the NXIVM -- when I left, I asked for a full 
accounting of what I owed them, what I had taken, and 
what they owed me through NXIVM 's attorneys in New York, 
and that was refused. 

Q What is the amount that you think NXIVM owes you? 

A Approximately 9,000. 

Q $9,000? 

A Yes . 

Q And you asked for 250? 

A That's a whole different thing. I believe they owe me 
9,000 for my April commissions. 



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Q All right. 

A And then based on NXIVM's teachings, I believe that there 
was a fair value that I built for them. And because 
NXIVM does not provide their independent contractors with 
contracts, I believe I wasn't protected. NXIVM didn't 
look out to protect me, nor did I look out to protect 
myself because it ' s preached that Keith is the most 
ethical person in the world. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) Do you think -- do you have any other 
claims that you assert against NXIVM for money? 

A I -- at this time, I haven't explored any damages beyond 
that . 

Q Do you think that you've been damaged in any way by NXIVM 
other than the $9,000 you were referring to? 

A I haven't even talked to an attorney about that. 

Q I mean, do you have in the back of your mind any 
suspicion or hint that you've been damaged? 

A I have some hypothesis. 

Q What are they? 

A Consumer fraud for number one. 

Q So you felt you were defrauded in what? 

A In the fact that they sold Keith as one thing, and then I 
find out information that he's not that at all. 



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Q How much money did you spend that you think you were 

defrauded out of? 
A I don ' t know . 

Q I mean, is it a thousand dollars? 
A No. It was probably closer to 40. 

Q $40,000. How else do you think -- what other kind of 

theories do you have against NXIVM? 
A Possibly emotional abuse. 
Q Who abused you? 

A Mostly Nancy Salzman and -- Nancy Salzman, Karen 

Unterreiner, Lauren Salzman, but mostly Nancy. 
Q Did they abuse you directly? 
A Yes . 

Q By calling you a suppressive? 
A Amongst other things . 

Q What are the other things they called you? 

A Well, it's not so much what they called me. It's a lot 

of what they did to me in the company. 
Q I see. What did they call you that you thought was 

abus i ve ? 

A Well, Lauren at one particular training called -- well, 
I've answered some of those. Suppressive, defiant, a 
compulsive liar, emotionally dishonest, rule bound, 
slimy, those kinds of things. 

Q Who said you were slimy? 



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A Lauren Salzman told me that her mother said that. "You 

appear really slimy right now." 
Q "You appear really slimy"? 
A Yes . 

Q That's what she said? 

A I think that's what she said. 

Q What other bad things were said about you? 

A It's not so much all the stuff that was said about me. I 
think that emotional abuse has a continuum and a 
spectrum, and there were a lot of things done that I 
believe are emotional abuse. 

Q What was the most emotionally abusive thing to ever 
happen to you at NXIVM? 

A Hm, that's a good guestion. Let me think. 

I think my overall treatment by Nancy Salzman. And 
in regards to going into this any further, I don't know 
how it pertains to what we're talking about today, and 
I'd rather not go into that any further until I've had a 
chance to talk to an attorney about that. I don't know 
how it's pertinent to my permanent injunction. 

Q So you're unwilling to tell me how you think NXIVM' s 
abused you? 

A I don't have an attorney present. The judge isn't 

available, and I don't know if this line of guestioning 
is a line of guestioning that an attorney wouldn't object 



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to if I had one. And based on your asking me to bring my 
attorney's e-mails, I'm not sure that this is in my best 
interest to follow this line of questioning. 

Q Well, your declaration is just filled with claims that 

you've been abused by NXIVM, and you're unwilling to tell 
me what they all are? 

A Do you want to point those out, and we can discuss those 
particular claims? 

Q No. I'm asking you to tell me if you, you know -- 

A Well, if you want to point those out, I'd be more than 
glad to explore that particular thing, and then I can 
talk to you about what I meant when I wrote that. 

Q Can you think of any other way in which -- any specific 
way in which you think you were abused by NXIVM? I mean 
the most significant thing that happened to you in terms 
of emotional abuse. 

A I think just the overall lie that they're one thing and 
they 're no t . 

Q I mean give me the most terrible thing that happened to 
you in NXIVM that you consider abusive. 

A Well, I think the mere fact that they present themselves 
as a human potential program that has answers to 
mankind's problems and that Keith is the most ethical man 
that you could ever come across and that he would never 
do anything to harm you, in relationship to that. And 



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when I asked for contracts, like why don't we have any 
contracts in regards to what it means to be a field 
trainer, what does it mean to be a proctor, how are these 
things protected, I was constantly questioned about my 
loyalties to Keith instead of addressing the real issue. 
Like, why didn't we have contracts to protect our 
investments ? 

Q And that's your answer? 

A That's part of my answer. 

Q Well, give me the whole answer. 

A That's the best -- well, that's all I can talk -- 
Q Is that all you can think of today? 

A That's all I can think of today besides the other things 
that I've talked about. 

Q Do you think that NXIVM should tell each potential 

customer everything about Keith Raniere ' s personal life 
before the customer comes in as a client? 

A Well, I think the thing is, is that based on his 

position, it's kind of like, you know -- there are 
certain positions in the world where I think people have 
a right to know certain things. Like, if I want to 
invest my money, I think it would be better to know 
Bernie Madoff's behaviors -- 

Q His sexual history? 

A -- before I invested -- 



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Q His sexual history? 

A No, his financial history. 

Q Well, I'm talking about sexual history. Do you think 

that, for instance, that we should know everything there 
is to know about President Obama ' s sexual history before 
we vote for him? 

A The thing is, is that the president is -- has a different 
position in the world. Keith has a position where he's 
in -- him and his company and Nancy Salzman are in 
people's emotional lives, and I think that people have a 
right to know the moral fiber of somebody that they put 
that trust into. 

Q Well, start with President Obama. But for example, do 
you think that you ought to know everything there is to 
know about President Obama ' s sexual history before voting 
for him? 

A I think if he lied and manipulated women, I think that I 
have a right to know that, and that often is made 
public -- 

Q Well -- 

A -- about our politicians. 

Q -- suppose he doesn't say anything. Do you think you're 
entitled to know everything there is to know about his 
sexual history? 

A I think if somebody finds that that -- 



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Q Really? 

A -- that their experience with President Obama was 

sexually abusive, that they -- and they come forward that 
people have a right to know about that . 

Q Well, suppose it's just not sexual abusive; it's just 

that he ' s got five women on the string at once . Do you 
think you're entitled to know that before you vote for 
him? 

A I think that I am because that points directly to the 

moral fiber of the person who's in charge of running our 
company -- or, I mean, our country. 

Q Do you think that if you had -- if you decided to engage 
a psychiatrist for therapy that you should ask him to 
give you a disclosure as to his sexual history before you 
do so ? 

A If it was dis- -- that if it was discovered that he 
manipulated women, I wouldn't choose him as my 
psychiatrist . 

Q Well, I'm not talking about discovery. I'm just saying, 
do you think that if you're going to go and talk to a 
psychiatrist about depression or anxiety or something 
like that that you have the right to ask him, "Do you 
mind telling me what your sexual history is?" 

A You know, I have never considered that. 

Q All right. So here you've got Keith Raniere, who's 



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running a human potential growth program -- like, Tony 
Robbins, for instance, do you think if you'd gone to Tony 
Robbins ' s organization that you should say, "You know, 
Mr. Robbins, before I sign on to your program, could you 
just tell me whether you're straight or gay, whether 
you've got multiple partners or single partners, whether 
you're celibate or what?" 

Do you think you are entitled to ask those kind of 
guestions of him? 

A You know, before my experience of NXIVM, I would have 

never considered that, but that's one thing that I will 
investigate before ever becoming involved in another 
company like that. 

Q So you think -- so just to kind of sum up your testimony, 
you believe that you've been abused and mistreated 
because you found out that Keith Raniere was not the 
celibate saint that you thought that he had been 
portrayed as? 

A It's not just the celibacy thing. I mean, it's really 

around the manipulation that I believe that he does with 
women, and it's the manipulation that he does with his 
members to extract money out of them to gamble in the 
commodities market. I think that those are immoral 
things -- 

Q Do you even know that -- 



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A -- and there's a conflict of interest. 

Q Do you even know how to make a trade in the commodities 

market ? 
A No . 

Q Who are you to say -- what basis do you have to claim 

that an investment in the commodities market is gambling? 
A 70 million is -- to me -- in my opinion is a gambling. 
Q Do you know how those -- 
A To lose 5 million is a gamble. 
Q Do you know how he made those trades? 

A I don't. I know that he lost 1.7 of Barbara Bouchey's 
money from her telling me that. He promised to pay it 
back and never did and then never -- she never got a 
contract because he was sold to her as the most ethical 
man in the world. 

And then when she asked for it back, his thing was, 
"I thought it was a gift." 

Q So it sounds like to me that basically you've kind of 

thrown in with a bunch of Keith Raniere ' s ex-girlfriends 
who are angry with him about his sexuality, and you've 
kind of signed on to the notion that he's just a bum 
because he has other girlfriends. I mean, can you see 
that? 

A It's not that. It's not the fact that he has more than 
one girlfriend. 



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Q Well, can you tell me where NXIVM has ever claimed to 
represent that its founder should be monogamous or 
celibate ? 

A It's not about the monogamy. It's more -- 
Q No. Try and answer the question. Have you ever heard 
any claims by NXIVM or any of its writings that NXIVM' s 
members, let alone its founder, should be celibate or 
monogamous ? 
A Can you ask me that again? 

Q Yeah. Have you ever heard any publication or seen any 
publication of NXIVM saying that "One of our ethical 
tenants is that you're expected to be celibate or 
monogamous " ? 

A And again, it's not about that. If he had -- 
Q NXIVM is not about that at all, is it? 

A Well, the thing is, is that if it was just the monogamy 
issue, if he was nonmonogamous , then that would be a 
different issue. But the thing is, is the manipulation 
that goes behind the nonmonogamy. 

Q Well, let's deal with the monogamy first. So is it 

correct to say you've never seen any teaching by NXIVM or 
ESP stating that its members should be celibate or 
monogamous ? 

A I -- no. They don't talk about celibacy or monogamy. 
Q So in their teachings, in their intensives and their 



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programs, NXIVM takes no position one way or the other as 
to whether you should be straight or gay or celibate or 
monogamous; correct? 

A It would be different if I was just a student. 

Q Am I correct? 

A It would be different -- 

Q Am I correct? 

A I'm trying to answer your question. 
Q No. No. The question is -- 

A Well, you're asking me a narrowly focused question -- 
Q Yeah. But -- 

A -- to lead to one certain answer, but it's more than 

that, and that's what I'm trying to say, Mr. Crockett. 

Q All right. So let me -- you're trying to tell me -- let 
me try again. Are you aware -- let me try again. I'm 
sorry . 

Is it correct to say then that as far as you can 
tell in NXIVM ' s philosophy that NXIVM takes no position 
as to whether one should be straight or gay or celibate 
or monogamous? Is that correct? 
A But they seem to take the position that it's okay to 
manipulate people, and that was my issue. 

MR. CROCKETT: Move to strike as 

nonresponsive. 

Q (By Mr. Crockett) Let's try again. Is it correct to say 



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that NXIVM takes no position as to whether one should be 
straight, gay, monogamous, or even married; correct? 

A As a company, I don't believe they take those positions. 

Q All right. So now let's go on to your point, and that's 
manipulation . 

All right. Does -- if NXIVM takes no position on 
one's sexuality or orientation, then explain to me how 
Mr. Raniere has engaged in manipulation contrary to the 
ethics of NXIVM. 

A It's not just about that. I mean, it's him as an 

individual who is the leader of this company. To find 
out that somebody of his position has taken advantage of 
women through the actual aspect of people divulging their 
emotional issues within the curriculum, I believe is 
abuse . 

If I was in -- I spent ten years in the Navy. If my 
commanding officer behaved that way, he would be held 
accountable for that. He would probably be discharged 
dishonorably from the military by behaving that way. 

Q Well, we're not talking about the military. We're 

talking about an ethical setup that -- construct that 
NXIVM has created, and -- 

A But it's a company that I worked for. 

Q Well, okay. So I guess my question is: You think -- 

let's look at Barbara Bouchey. Barbara Bouchey, she had 



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an advanced degree; correct? 
A I don ' t know that she had an advanced degree . 
Q She had a successful business; correct? 
A From what I understand, yes . 

Q She controlled tens of millions of dollars; correct? 
A From what I understand, yes . 

Q She was a certified financial planner; correct? 
A Correct . 

Q She had a million dollar home; correct? 
A From what she said, yes . 

Q All right. So you're telling me that you're offended 
that this woman was manipulated by some guy who doesn't 
even have a house, doesn't even drive a car? Really, 
you're offended by that? 

A Yes . 

Q Okay. 

A And it's not about him not having a house, not having a 
car. He's provided with all of those things through 
NXIVM members and Nancy Salzman. So it's not like he's, 
like, this homeless monk carrying a bull around in a loin 
cloth. The thing is, is Keith Raniere ' s needs are taken 
care of. 

And the thing is, is that just because somebody's 
successful in the financial realm does not mean that 
they're necessarily successful emotionally. 



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Q All right. So tell me how you know Keith Raniere 

manipulated Barbara Bouchey. 
A Based on my conversations with her and also based on my 

conversations with Esther Chiappone. 
Q Well, let's deal with the manipulation. How was poor 

Barbie Bouchey manipulated by Keith Raniere. 
A I -- well, you would have to ask her that, but if -- do 

you want my opinion of how I believe that happened? 
Q I'm not -- no. I'm asking for your evidence. I'm not 

asking for your opinion. You've been saying repeatedly 

that Keith Raniere manipulates people, and I'd like to 

focus on one person -- 
A Okay. 

Q -- the person you've spent most time with -- 
A Okay. 

Q -- Barbara Bouchey. 
A Okay. 

Q How was she manipulated? 

A My understanding is, is that when Barbara got together 
with Keith that she believed that she was Keith's 
girlfriend and only girlfriend and that Keith -- that 
they were dating, but they kept it a secret because -- 
for whatever reason. I don't know why they kept it a 
secret . I don ' t know why you would keep that a secret 
from anybody. Like, why was the -- why was the NXIVM 



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community not allowed to know that they were dating, that 
I don't know, but they kept it a secret. 

And then when Barbara Bouchey found out that Keith 
was not just her boyfriend and that Keith Raniere was 
sleeping with multiple women and confronted him, the 
thing that happened is, is that Keith then sent in his 
troops to deal with her and her disintegration around 
monogamy /nonmonogamy and that Keith having a sexual 
relationship with somebody else was no different than 
playing tennis. To me, that is manipulation. 

Q Did you see Keith Raniere sending in his troops to -- are 
these shop troops or something? 

A Pardon? 

Q Did you see Keith Raniere sending in his troops against 
Ms . Bouchey? 

A No. But I know that they -- that several people dealed 

[sic] with her emotional reactions. 
Q What -- so you didn't see him send in troops against 

Barbara Bouchey, but you know it happened? 
A Well, the thing is, is I had no reason to not believe 

Barbara Bouchey because things like that happened within 

the company. 
Q Okay. 

A There would be times when I would have a disagreement 

with Nancy, and then what would happen is before I knew 



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it Karen Unterreiner was calling me. 
Q No. Let's — 
A Clare -- 

Q Let's focus on Barbara Bouchey . 
A Okay. 

Q What did Barbara Bouchey say Keith Raniere did to send in 
the troops against her when she found out that he was not 
monogamous ? 

A Then what would happen is, is that multiple people would 
come to her house and do what they call explorations of 
meaning with her. And they would work with her on her 
disintegration around monogamy, nonmonogamy, and that it 
was okay for Keith to have multiple relationships . 

Q So that's a bunch of jargon, but I think what you're 
telling me is that -- 

A Well, I believe that that's a form of mind control. 

Q Well, I think what you're telling me is that Keith sent 
friends over to her house to try to persuade her that 
monogamy is no big deal and that she ought to accept -- 

A Well, these are more than just friends. These are people 
that know your internal workings on an emotional level . 

Q All right. 

A And then those things, if used incorrectly, can be used 

against somebody. 
Q So what it sounds like you're saying is that she allowed 



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herself to open up emotionally to these other people who 
knew about her, and they came in to work her over on the 
issue of monogamy; is that correct? 

A It's the nature of the company -- 

Q All right. 

A -- that people open themselves up. That's -- it's a 

human potential company where people do open themselves 
up . 

Q Who -- Yeah. Who did Keith Raniere send in to work her 
over on monogamy? 

A My understanding is Nancy Salzman was one. Lauren 

Salzman was another. Pam Cafritz was another. Karen 
Unterreiner was another, and Becky Friedman was another. 

Q And your understanding -- 

A And Kristin Keefee was another. 

Q And your understanding is based on who? 

A Barbara Bouchey. 

Q Okay. Everything Barbara Bouchey told you? 

A Well, I don't have any -- based on my understanding of 

NXIVM, I have no reason to not believe her. 
Q Okay. So what other women were -- do you have evidence 

were manipulated by Keith Raniere? 
A Esther Chiappone. 
Q Spell that last name. 

A I don't know how to spell it. It ' s on one of the 



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e-mails . 

Q Was she a former girlfriend? 

A You know, I don't know what her status with Keith was. 
Q How was she manipulated? 

A Esther and I were students in our very first intensive 

together, and Esther -- from my understanding of having a 
conversation with Esther, is Esther was led to believe 
that Keith was attracted to her and that she, based on my 
understanding, was attracted to him. 

Esther divorced her husband and moved her four kids 
from Sterling, Alaska, to Albany, New York, to be with 
Keith. And then my understanding, based on my 
conversation with Esther, is Esther found out that Keith 
was nonmonogamous , had a reaction to that, and then from 
my understanding, Nancy Salzman was sent in to deal with 
her . 

Q And what's that understanding based own? 
A My conversations with Esther. 

Q Esther. All right. So what bad thing did Nancy Salzman 
do to Esther? 

A Well, I was -- actually happened to be at an intensive in 
Anchorage, Alaska, right after that happened. That's 
when Esther talked to me. And Nancy did what I believe 
is her form of mind control, same thing she did with me 
when I wouldn't behave the way she wanted me to. 



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Q And what ' s the mind control she used? 

A Nancy's an expert at NLP. She was a master trainer for 
master trainers in NLP. If NLP is used inappropriately, 
it can be used as a weapon of mind control . 

Q Now, what did you see that she used against Esther? 

A That. Just that. 

Q Explain to me -- no. Explain to me what you saw Nancy do 
to Esther that you considered to be mind control. 

A Well, my experience of that training is, is that Nancy 
was very abusive to Esther. 

Q And so you saw this for yourself? 

A Yes . 

Q Explain to me what happened. 

A Yelling, screaming, you know, all of those different 

kinds of things . 
Q About what topics? 

A Esther and I had a conversation the night before. I -- 
the next day I was in the bathroom with Nancy, and Nancy 
came in in a fury asking me about my conversation with 
Esther. "What did you talk about? I need to know what 
you talked about." Those kinds of things. And I'm 
like — 

Q No. I want you to focus on what Nancy told Esther. 

You're talking about all of these other things. What did 
you see Nancy do to Esther that constituted manipulation? 



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A I saw Nancy being angry at Esther. 
Q So she was mad at her? 
A Right. 

Q Over what topic? 

A I think the thing is she was afraid Esther was going to 

spill the beans -- 
Q No. No. 

A -- about the sexual -- 

Q She was angry. Did she say what -- did Nancy say what 

she was angry about? 
A To me? She just asked me what we had talked about. 
Q No, no, no, no, no. In front of Esther, did you see what 

Nancy did in front of Esther which constituted anger? 
A No . 
Q No. 

A It was just based on my conversation with Esther. 
Q Esther. 

A And based on all of these things -- 
Q I see . 

A You add all of these tings together, and there's a 
pattern . 

Q I see. You never saw Nancy be angry with Esther? 

A No, that's not true. I did see Nancy be angry with a lot 

of people . 
Q No. I'm talking about Esther. 



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A Yes . I did see her be angry -- 

Q Did you ever see Nancy be angry with Esther over 
monogamy? 

A Those actual conversations never took place in public. 

Q Did you ever see that? 

A But based on -- no, I didn't. 

Q All right. So what other women do you think were -- 
A Can I finish that? 

Q Well, you said no. I don't want to hear the hearsay. 

So what other woman was manipulated? 
A Those are the two -- oh, and Toni Natalie. 
Q But Toni Natalie's never been a member of NXIVM. 
A That's not true. Toni Natalie was a green when she left 

NXIVM. She was a senior proctor. 
Q When did she leave NXIVM? 

A Before I got there. I don't know for sure when she left. 

When she left Keith, she left NXIVM. 
Q So you weren't even around when she and Keith split up -- 
A That correct ' s . 
Q -- correct? 
A That ' s correct . 

Q So you had no firsthand knowledge at all as to how she 

was manipulated? 
A I believe that there are too many similarities for this 

to be -- 



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Q Just answer my question. 
A -- just hearsay. 

Q She wasn ' t even around when -- 

A No, she wasn't, but I have -- I have talked to her since 

then . 
Q Sure. Now -- 
A And so there's a pattern. 

Q So you've only mentioned three women, two of whom you 
believe slept with Keith, and the third you don't 
think -- 

A No . 

Q -- there's evidence of -- 

A I also -- I also mentioned Kathy Ethier, that I believed 

that Keith was inappropriate with Kathy Ethier. 
Q Okay. And did Kathy Ethier sleep with Keith Raniere? 
A That, I do not know. 

Q All right. So you've only identified, in terms of 

manipulation, two women -- 
A Right. 

Q -- who actually slept with Keith Raniere. 

A No. I have mentioned three. 

Q Three over a period of ten years . 

A Right. 

Q Okay. 

A Well, the other thing is, though, in regards to that -- 



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can I finish this? Are you going to let me finish? 
Q I asked you over ten years. You said yes. There's no 

guestion pending. 
A But there's a pattern. 

Q No guestion pending. I know you -- I know you believe 
there's a pattern. 

All right. Just a second. I'm almost done. 
Do you have any evidence that Keith Raniere was 
involved in compulsive gambling outside of investing in 
the commodities market, like, for instance, casino 
gambling or Black Jack or cards or anything like that? 
A No, but I can get an affidavit. 
Q What? 

A I said no, but I can get an affidavit. 

Q From who? 

A From Toni Natalie. 

Q And what do you think Toni Natalie would say? 
A That he gambled at the casinos. 

Q And certainly you have no evidence of that; correct? 
A I never saw him. 

Q So gambling at casinos is considered an affront to 
NXIVM's ethical system? 

A Excuse me. I think based on Keith's position in the 

company -- and I've stated this several times -- is that 
taking members' -- like for me it's like taking members' 



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money and utilizing it in that capacity is not only 
unethical, but it's a conflict of interest. 

Q Do you think that Keith ever took NXIVM members ' money to 
gamble at the casinos? 

A That, I don't know. 

Q Do you think that's what -- 

A It's possible . 

Q -- Natalie is going to say? 

A I don't know what she's going to say. 

Q Well, you said you had an affidavit -- or you could get 
an affidavit . 

A No. I can get an affidavit. What she'll say in it, I 
don ' t know . 

Q And is it correct to say that you have no clue as to how 

a commodities transaction is executed? 
A I don't know how that is, but I think 70-plus million 

dollars is a lot of money to lose in the commodities 

market . 

Q So you're basing your conclusion that he's a compulsive 
gambler on the amount of money that he lost? 

A And based on my conversations with Yuri Plyam and Barbara 
Bouchey, based on how he did that and the amount of time 
that he did that. In my opinion, based on what I know, 
that that's an addictive problem. 

Q What do you think -- well, what did Yuri Plyam tell you 



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that led you to conclude that Keith Raniere was a 

compulsive gambler? 
A That he would hedge bets that were -- didn't make any 

sense, that didn't make any logical sense, and the amount 

of money that he would lose in a day. 
Q He used the word "hedge bets"? Do you even know what 

that term means? 
A No. My assumption is, is that when you hedge a bet is 

that you take a risk on something going one way and that 

if it doesn't then you lose your money. 
Q No. 

A That's my understanding. 

Q No. The word "hedge bet" means that you -- you're 
protecting against a bet that you've made. It's the 
opposite of what you've just said. 

A Okay. 

Q So did Yuri use the word "hedging bets" with you? 

A That I can recall . 

Q He said he hedged bets? 

A That's what I recall. Whether he said that or not -- 
Q Did you know that a gambler who hedges bets is a very 

conservative gambler? 
A I don't consider losing $70 million in a short period of 

time conservative. 
Q Well, I'm just trying to determine what exactly Yuri 



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Plyam told you that would lead you to believe Keith 
Raniere was a compulsive gambler other than the amount of 
money that was lost. 
A Well, then you might want to ask Yuri that. 

Q No. I'm asking you. I'm asking you what you recall Yuri 
told you. 

A That he -- Keith would bet millions of dollars in a day 
and lose it. To me, that's a compulsive gambling 
problem . 

Q And tell me what expertise you have in determining 

compulsive gambling. 
A Well, my expertise is, is that for six years in the 

United States Navy, I worked in the addictions field, and 

I think I have a pretty good understanding of addictive 

nature and addictive problems. 
Q How many compulsive gamblers did you work with? 
A I didn't work with any compulsive gamblers. I worked 

with people who were addicted to alcohol and drugs, but 

the addiction cycle is the same in overeating, gambling, 

sex, all different kinds of things. 
Q Is there a DSM publication on compulsive gambling? 
A I'm sure there is. 
Q Okay. Have you read it? 
A Not in a long time . 
Q Have you ever read it? 



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A Yes . 

Q So you've never treated a compulsive gambler? 

A We had people that came into the treatment facility that 
I worked at that had not only -- they were called 
poly-addicted. So they were not only addicted to 
alcohol, drugs, sometimes sex, sometimes gambling, 
sometimes food. So we dealt with all different types of 
addictions . 

Q Did you have your master's degree in psychology when you 

were in the Army? 
A In the Navy. 
Q In the Navy. 
A No, I didn't. 

Q You had a degree -- did you have your degree in holistic 

heal ing ? 
A No . 

Q Did you have any degree when you were in the Navy? 

A I got my associate's degree when I was in the Navy, but I 



was trained within the Navy treatment facility program. 
Q So -- 



MR. CROCKETT: All right. Just a 



second . 



Let's take a five-minute break. 



THE VIDEOGRAPHER : As we go off the 



record, the time is 3:04. 



(Recess 3:04 



- 3:08 p.m.) 



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THE VIDEOGRAPHER : Okay. We are back 
on the record. The time is 3:08. 

EXAMINATION (Continuing) 

BY MR. CROCKETT : 

Q Okay. Ms. Dones, you made two filings in the bankruptcy 
court as a pro se . One was the -- your big declaration, 
and the other was for time for the continuance of the 
hearing and your deposition. Do you recall that? 

A Mm-hm. 

Q Did Ms. Bouchey help you on both of those documents? 
A She didn't help me on the declaration, and I don't 

believe she helped me on my extension. Her plate is 

pretty f ul 1 . 

Q But you talked to her about both before you did it, 

correct, before you did each one? 
A I don't think I talked to her about my declaration at 

all. I think -- and I don't recall talking to her about 

my continuance. 
Q Did -- 

A It's possible I did, but I am not recalling that right 
now . 

Q Did Mr. O'Hara help you with either one of those, give 
you advice? 



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A I told you we talked about that with this. 

Q Well, I'm now talking about both the declaration and the 

application for continuance. 
A I don't think he helped me with the application for 

continuance . 

Q Well, somewhere you would have had to have gotten the 
idea that I was a table pounder and a screamer and 
wouldn't let people go to the bathroom. 

A And I have answered that question. 

Q Well, so somebody must have helped you with that. 
A And I answered that question. 
Q Who was that? 

A That was Barbara Bouchey's rendition of her first 

deposition with you. 
Q Okay. So you -- so Barbara Bouchey had some input with 

respect to the application for the continuance; correct? 
A Based on that, but she didn't say "Put that in your 

thing . " 
Q All right. 

A I just remember that conversation when you first deposed 

her. I think it was in the Plyam case -- 
Q Yeah. Right. 
A -- back in New York. 

Q Now, did Mr. Skolnik give you advice on the first 
application, the application for a continuance? 



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A No . 

Q Did Mr. O'Hara give you advice on either one of those 
two? 

A The -- on the -- 

Q The application for continuance and the declaration. 
A Yeah. He helped me with this one. We talked -- 
Q Yeah. How about the other one, the -- 

A No, I don't believe so. Actually, I asked the court 

clerk a lot of questions about how to even go about that. 
I didn ' t know -- 

Q Okay. 

A -- how to go about that. 

Q So I'd like to conclude this deposition, and I'd like to 
propose to you that we treat this transcript 
confident ial . 

A I don ' t agree to that . 

Q All right. Is there a reason why not? 

A Because I believe that it should be a public record. 

Q And so it's your intention to publish this transcript 
on -- in public? 

A I don't publish any transcripts. I don't publish any 

documents, but I do have an issue with preventing people 
from knowing. So if the judge decides to seal it, I will 
abide by that, but I don't agree to seal anything. 

Q Will you agree not to release the transcript to any third 



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party other than your lawyer? 
A Absolutely. 
Q You will agree to that? 

A I will not -- I will not give the transcript to anybody 
other than my attorney or if I'm subpoenaed that in 
another case . 

Q Okay. If you're willing to agree to that, then that's 
great . 

Will you be willing to sign a stipulation to that 
effect? 

A Once I can review what the implications of that are, I 
absolutely will. Just kind of like when you sent me 
those -- the proposal -- 

Q Yeah. 

A -- for -- to get out of the deposition today -- 
Q Yeah. 

A -- what that would take, if you send me that, I will read 
through that and do some research on the internet of what 
exactly I am signing. 

Q Are you going to show this transcript to Ms. Bouchey? 

A No . 

Q To Yuri Plyam? 
A No . 
Q To -- 

A I haven't seen anybody's -- I've never seen a 



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transcript -- 
Q Yeah. 

A -- except for the ones -- I think there's one on Nancy -- 
on the internet. Other than that, I haven't seen 
anybody's transcript. 
Q And are you still abiding by the temporary restraining 

order provisions? 
A Yes, sir. I agreed to that, and I will do that. 

MR. CROCKETT: All right. I have no 
further questions of this witness. 

THE VIDEOGRAPHER : There being no 
further questions, at this time the deposition is 
concluded. This is the end of Disk No. 3. We are going 
off the record at 3:13 p.m. Thank you. 

(Signature reserved.) 
(Deposition concluded at 
3:13 p.m.) 



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STATE OF WASHINGTON ) I, Valerie L. Torgerson, CCR, RPR, 

) ss a certified court reporter 
County of Pierce ) in the State of Washington, do 

hereby certify: 



That the foregoing deposition of SUSAN F. DONES 
was taken before me and completed on November 23, 2010, and 

thereafter was transcribed under my direction; that the 
deposition is a full, true and complete transcript of the 
testimony of said witness, including all guestions, answers, 
objections, motions and exceptions; 

That the witness, before examination, was by me 
duly sworn to testify the truth, the whole truth, and 
nothing but the truth, and that the witness reserved the 
right of signature; 

That I am not a relative, employee, attorney or 
counsel of any party to this action or relative or employee 
of any such attorney or counsel and that I am not 
financially interested in the said action or the outcome 
thereof; 

That the transcript will be securely sealed, and 
the said deposition will be promptly delivered to 
Attorney Robert D. Crockett. 

IN WITNESS WHEREOF, I have hereunto set my 
signature on the 24th day of November. 



Valerie L. Torgerson, CCR, RPR 
Certified Court Reporter No. 2036.